Hafezy v. Garland et al

Filing 15

Order by Magistrate Judge Lisa J. Cisneros granting #14 Stipulation to Extend Time for Defendants' Response to Plaintiff's Complaint. Defendant's Response due by 10/16/2024.(bns, COURT STAFF) (Filed on 9/25/2024)

1 ISMAIL J. RAMSEY (CABN 189820)
United States Attorney
2 PAMELA T. JOHANN (CABN 145558)
Chief, Civil Division
3 ELIZABETH D. KURLAN (CABN 255869)
Assistant United States Attorney
4
450 Golden Gate Avenue, Box 36055
San Francisco, California 94102-3495
5
Telephone: [phone]
Facsimile: [phone]
6
[e-mail]
7
Attorneys for Defendants
8
UNITED STATES DISTRICT COURT
9
NORTHERN DISTRICT OF CALIFORNIA
10
SAN FRANCISCO DIVISION
11
HAMED HAFEZY,
Case No. 3:24-cv-04584 LJC
12
Plaintiff,
13
v.
STIPULATION TO EXTEND TIME FOR
DEFENDANTS’ RESPONSE TO
14
MERRICK B. GARLAND, in his official
PLAINTIFF’S COMPLAINT; AND ORDER
15 capacity as Attorney General, United States
Department of Justice, et al.,
16
Defendants.

17
18
19
20
21
22
23
24
25
26

The parties, through their undersigned attorneys, hereby stipulate to an extension of time for
Defendants’ response to Plaintiff’s complaint. Defendants will file their response on or before
October 16, 2024.
The parties further request a corresponding extension on the deadline for filing a motion for
summary judgment under the Court’s Immigration Mandamus Procedural Order. Dkt. No. 7. Currently,
Defendants must file a motion for summary judgment by 120 days after the complaint was served, or
November 28, 2024. In view of the agreed-upon extension for Defendants’ response to the complaint,
the parties request that Defendants must file their motion for summary judgment by December 16, 2024.

27
28

Stipulation to Extend
C 3:24-cv-04584 LJC

1

1 Dated: September 24, 2024

Respectfully submitted, 1

2

ISMAIL J. RAMSEY
United States Attorney

3

/s/ Elizabeth D. Kurlan
ELIZABETH D. KURLAN
Assistant United States Attorney
Attorneys for Defendants

4
5
6
7 Dated: September 24, 2024

/s/ Zachary Nightingale
ZACHARY NIGHTINGALE
Van Der Hout LLP
Attorney for Plaintiff

8
9
10
11
12

ORDER
Pursuant to stipulation, IT IS SO ORDERED.

13
14 Date: September 25, 2024

______________________ ____
LISA J. CISNEROS
United States Magistrate Judge

15
16
17
18
19
20
21
22
23
24
25
26

1
In accordance with Civil Local Rule 5-1(i)(3), the filer of this document attests that all
27 signatories listed herein concur in the filing of this document.

28

Stipulation to Extend
C 3:24-cv-04584 LJC

2

DECLARATION OF ELIZABETH D. KURLAN

1
2

I, Elizabeth D. Kurlan, declare and state as follows:

3

1.

I am an Assistant United States Attorney in the United States Attorney’s Office for the

4 Northern District of California and counsel of record for the federal Defendants in the above-captioned
5 action.
6

2.

On July 29, 2024, Plaintiff filed a complaint in which he seeks adjudication of his

7 parents’ applications for immigrant visas. See Dkt. No. 1. Our office was served with the complaint on
8 July 31, 2024.
9

3.

On September 9, 2024, my office contacted Plaintiff’s counsel regarding Defendants’

10 request for an extension of time to prepare their response to the complaint, and Plaintiff consented to the
11 request.
12

I declare under penalty of perjury under the laws of the United States of America that the

13 foregoing is true and correct.
14
15 DATED: September 9, 2024

/s/ Elizabeth D. Kurlan
ELIZABETH D. KURLAN
Assistant United States Attorney

16
17
18
19
20
21
22
23
24
25
26
27
28

Stipulation to Extend
C 3:24-cv-04584 LJC

3