Cardenas-Reyes et al v. Mayorkas

Filing 17

ORDER granting 16 Stipulation to Extend Time for Defendant to file Motion for Summary Judgment: Defendant shall file his motion for summary judgment by 11/21/2023. Signed by Chief Magistrate Judge Donna M. Ryu on 11/15/2023. (ig, COURT STAFF) (Filed on 11/15/2023)

1 ISMAIL J. RAMSEY (CABN 189820)
United States Attorney
2 MICHELLE LO (NYRN 4325163)
Chief, Civil Division
3 ELIZABETH 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 Defendant
8
UNITED STATES DISTRICT COURT
9
NORTHERN DISTRICT OF CALIFORNIA
10
OAKLAND DIVISION
11
12
13
14
15
16

SANTOS YOVANNY CARDENAS-REYES,
et al.,
Plaintiff,
v.
ALEJANDRO MAYORAKS, Secretary, U.S.
Department of Homeland Security,

17

4:23-cv-03038 DMR
STIPULATION TO EXTENSION OF TIME FOR
DEFENDANT’S MOTION FOR SUMMARY
JUDGMENT; ORDER

Defendant.

18
19
20
21
22

Pursuant to Civil Local Rule 6-2, the parties to this action hereby stipulate to an extension of
time for Defendant to file his motion for summary judgment. Defendant will file his motion for
summary judgment by November 21, 2023. For these reasons, and as articulated below in the
Declaration of Counsel, the parties respectfully request that the Court grant their stipulation.

23
24
25
26
27
28
Stipulation
4:23-cv-03038 DMR

1 Dated: November 14, 2023

Respectfully submitted, 1

2

ISMAIL J. RAMSEY
United States Attorney

3

5

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

6

Attorneys for Defendant

4

7
8 Dated: November 14, 2023

/s/ Kevin M. Crabtree
KEVIN M. CRABTREE
ASHLEY A. BYERS

9
10

Attorneys for Plaintiffs

11
12
13
ORDER

14

Pursuant to stipulation, IT IS SO ORDERED. Defendant will file his motion for summary

RT

20

onn
Judge D

21

u

A

H

ER

a M. Ry

R NIA

NO

19

D

RDERE

OO
IT IS S

FO

18

UNIT
ED

Date: November 15, 2023

S DISTRICT
TE
C
A
T

RT
U
O

17

S

16 judgment by November 21, 2023.

LI

15

N

F
D IS T IC T O
R

C

DONNA M. RYU
United States Chief Magistrate Judge

22
23
24
25
26
27

1

In accordance with Civil Local Rule 5-1(i)(3), the filer of this document attests that all
signatories
listed herein concur in the filing of this document.
28
Stipulation
4:23-cv-03038 DMR

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 District Court for the

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

2.

On September 15, 2023, Defendant filed his answer to the Complaint. See Dkt. No. 13.

7

3.

On November 14, 2023, I contacted Plaintiffs regarding Defendant’s request for a brief

8 extension of time to prepare their motion for summary judgment, and Plaintiffs consented to the request.
9

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

10 foregoing is true and correct.
11 DATED: November 14, 2023
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Stipulation
4:23-cv-03038 DMR

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