Bertos v. Napalitano et al

Filing 19

STIPULATION AND ORDER 18 to Extend Time to Answer. Signed by Judge Ronald M. Whyte on 12/13/12. (jg, COURT STAFF) (Filed on 12/13/2012)

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STUART F. DELERY
Acting Assistant Attorney General
DAVID J. KLINE
Director, District Court Section
Office of Immigration Litigation
ELIZABETH J. STEVENS
Assistant Director
CRAIG W. KUHN (VSB: 43539)
Trial Attorney
P.O. Box 868, Ben Franklin Station
Washington, D.C. 20044-0868
Telephone: [phone]
Facsimile: [phone]
e-mail: [e-mail]

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Attorneys for Defendants
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UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN JOSE DIVISION

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ATINA BERTOS,
Plaintiff,

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v.
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JANET NAPOLITANO, et al.
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Defendants.
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No. C 5:12-cv-3531-RMW

STIPULATION TO EXTEND TIME TO
ANSWER

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On July 6, 2012, Plaintiff filed the above captioned action. The United States Attorney’s

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Office was served on July 19, 2011. On September 14, 2012, the parties stipulated to extend time

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to answer by 45 days. Defendants’ answer to the complaint is due by November 2, 2012. The

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parties wish to continue their efforts to explore possible avenues of administrative remedies. The

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parties stipulate under Civil L.R. 6-1(a), to extend time for Defendants to answer the complaint by

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60 days from November 2, 2012, to and including January 2, 2013.

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Dated: October 26, 2012

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Respectfully submitted,
TONY WEST
Assistant Attorney General

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DAVID J. KLINE
Director

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ELIZABETH J. STEVENS
Assistant Director

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/s/ Craig W. Kuhn
CRAIG W. KUHN1
Trial Attorney
United States Department of Justice
Civil Division
Office of Immigration Litigation
District Court Section
Attorney for Defendants

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LAW OFFICE OF BERNADETTE CONNOLLY
Dated: October 26, 2012

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/s/ Bernadette Willeke Connolly (by email consent)
BERNADETTE WILLEKE CONNOLLY
1671 The Alameda, Suite 200
San Jose, CA 95126
Attorney for Plaintiff

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ORDER
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Pursuant to the stipulation of the parties, IT IS SO ORDERED.
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Dated:

, 2012

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__________________________________
Ronald M. Whyte
United States District Judge

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I, Craig W. Kuhn, hereby attest that I obtained the concurrence in the filing of this
document from all signatories indicated by a “conformed” signature (/s/).
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