Asian Law Caucus v. United States Immigration and Customs Enforcement et al

Filing 30

ORDER by Judge Saundra Brown Armstrong Granting 29 Stipulation (ndr, COURT STAFF) (Filed on 11/20/2013)

1 MELINDA HAAG (CSBN 132612)
United States Attorney
2 ALEX G. TSE (CSBN 152348)
Chief, Civil Division
3 JENNIFER S WANG (CSBN 233155)
Assistant United States Attorney
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450 Golden Gate Avenue, Box 36055
San Francisco, California 94102-3495
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Telephone: [phone]
FAX: [phone]
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[e-mail]
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Attorneys for Federal Defendants
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JESSICA KARP (CA BAR NO. 277347)
9 UC Irvine Immigrant Rights Clinic
c/o National Day Laborer Organizing Network
10 675 S. Park View St.
Los Angeles, CA 90057
11 Tel: [phone]
Fax: [phone]
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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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OAKLAND DIVISION

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ASIAN LAW CAUCUS,
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Plaintiff,
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v.
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UNITED STATES IMMIGRATION AND
CUSTOMS ENFORCEMENT; UNITED
STATES DEPARTMENT OF HOMELAND
SECURITY,
Defendants.

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CASE NO. 13-1593 SBA
STIPULATION TO EXTEND DEADLINES FOR
DISPOSITIVE MOTIONS
Hon. Saundra B. Armstrong

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The parties by and through their counsel of record, hereby stipulate and agree as follows:
1. On August 30, 2013, the Court set the following briefing schedule for summary judgment in the

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above-captioned case:

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Plaintiff’s motion for summary judgment due: December 10, 2013

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Defendants’ consolidated opposition/cross-motion for summary judgment due: January 7, 2014
STIPULATION TO EXTEND DEADLINE FOR DISPOSITIVE MOTIONS
C13-1593 SBA
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Plaintiff’s consolidated reply/opposition to defendants’ cross-motion for summary judgment due:

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January 21, 2014

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Defendants’ reply in support of cross–motion for summary judgment due: January 28, 2014

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Hearing on parties’ cross-motions for summary judgment: February 25, 2014 at 1:00 p.m.

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2. The federal government shutdown from October 1 through October 16, 2013 has delayed

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defendant U.S. Immigration and Customs Enforcement’s (hereinafter, “ICE”) expected

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production of documents in response to the Freedom of Information Act (“FOIA”) requests at

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issue. During the lapse in government appropriations, undersigned counsel for the defendant as

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well as ICE employees involved in the processing of the agency’s response to the FOIA requests

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at issue were furloughed.
3. The parties believe that ICE’s document production will dispose of the issues in this case, or

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narrow the issues for summary judgment. Accordingly, to allow ICE sufficient time to complete

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its production of documents prior to the deadlines for the parties’ cross-motions for summary

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judgment, the parties respectfully request that the dispositive motions schedule be extend as

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follows:

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Plaintiff’s motion for summary judgment due: February 18, 2014

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Defendants’ consolidated opposition/cross-motion for summary judgment due: March 11, 2014

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Plaintiff’s consolidated reply/opposition to defendants’ cross-motion for summary judgment due:

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March 25, 2014

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Defendants’ reply in support of cross–motion for summary judgment due: April 1, 2014

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Hearing on parties’ cross-motions for summary judgment: May 6, 2014, at 1:00 p.m.

22 IT IS SO STIPULATED.
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24 DATED: November 19, 2013
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Respectfully submitted,
MELINDA HAAG
United States Attorney
_/s/ Jennifer S Wang_______________
JENNIFER S WANG
Assistant United States Attorney

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STIPULATION TO EXTEND DEADLINE FOR DISPOSITIVE MOTIONS
C13-1593 SBA
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1 DATED: November 19, 2013

National Day Laborer Organizing Network

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/s/ Jessica Karp
JESSICA KARP
Attorneys for Plaintiff Asian Law Caucus

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ORDER

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Pursuant to the parties’ stipulation and good cause having been shown, it is hereby ordered that

7 the deadlines for the parties’ cross-motions for summary judgment are hereby extended as follows:
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Plaintiff’s motion for summary judgment due: February 18, 2014

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Defendants’ consolidated opposition/cross-motion for summary judgment due: March 11, 2014

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Plaintiff’s consolidated reply/opposition to defendants’ cross-motion for summary judgment due:

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March 25, 2014

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Defendants’ reply in support of cross–motion for summary judgment due: April 1, 2014

13 The parties’ cross-motions for summary judgment will be heard on May 6, 2014, at 1:00 p.m.
14 IT IS SO ORDERED.
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____________________________
SAUNDRA BROWN ARMSTRONG
United States District Judge

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STIPULATION TO EXTEND DEADLINE FOR DISPOSITIVE MOTIONS
C13-1593 SBA
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