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)

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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: (415) 436-7298 Facsimile: (415) 436-6748 6 Elizabeth.Kurlan@usdoj.gov 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

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