Ramirez Medina v. Asher

Filing 146

ORDER granting 145 Stipulated Motion to Extend Time for Defendants to Respond to Plaintiff's Third Amended Complaint. Response deadline continued to July 10, 2019. Signed by Judge Ricardo S. Martinez. (PM)

Case 2:17-cv-00218-RSM Document 146 Filed 06/05/19 Page 1 of 4

UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON
AT SEATTLE
DANIEL RAMIREZ MEDINA,
Plaintiff,
v.
U.S. DEPARTMENT OF HOMELAND
SECURITY, et al.,
Defendants.

Case No. C17-218 RSM-JPD
STIPULATION TO EXTEND TIME FOR
DEFENDANTS TO RESPOND TO
PLAINTIFF’S THIRD AMENDED
COMPLAINT AND ORDER

STIPULATION
Pursuant to LCR 10(g), Defendants U.S. Department of Homeland Security, et al., and
Plaintiff Daniel Ramirez Medina (together, “the Parties”), hereby stipulate to seek an order of the
Court extending the time for Defendants to respond to Plaintiff’s Third Amended Complaint
[ECF No. 140, filed May 30, 2019] by 4 weeks. Pursuant to Fed. R. Civ. P. 15(a)(3), Defendants’
current response deadline is June 12, 2019. Under the Parties’ stipulation, Defendants’ new
response deadline would be July 10, 2019.
Good cause exists to extend Defendants’ deadline where counsel for Defendants’ were
preparing for a hearing on May 31, 2019, which was ultimately canceled late in the day on May
30, and are presently preparing for a Ninth Circuit oral argument on June 13, 2019, in an appeal
of the DACA-related case, Inland Empire-Immigrant Youth Collective v. Duke, 2017 WL
5900061 (C.D. Cal. Nov. 20, 2017). Counsel for Defendants have additional filing deadlines as

STIPULATION TO EXTEND TIME FOR DEFENDANTS
TO RESPOND TO PLAINTIFF’S THIRD AMENDED COMPLAINT
AND ORDER

Case 2:17-cv-00218-RSM Document 146 Filed 06/05/19 Page 2 of 4

well as the upcoming July 4th holiday that further justify this requested 4-week extension to a
new response deadline of July 10, 2019.
ORDER
IT IS HEREBY ORDERED this 5th day of June 2019.

A

RICARDO S. MARTINEZ
CHIEF UNITED STATES DISTRICT JUDGE

STIPULATION TO EXTEND TIME FOR DEFENDANTS
TO RESPOND TO PLAINTIFF’S THIRD AMENDED COMPLAINT
AND ORDER

Case 2:17-cv-00218-RSM Document 146 Filed 06/05/19 Page 3 of 4

DATED: June 4, 2019 Respectfully submitted,
CHAD A. READLER
Acting Assistant Attorney General
WILLIAM C. PEACHEY
Director
JEFFREY S. ROBINS
Deputy Director

/s/ James J. Walker
JAMES J. WALKER
Trial Attorney
U.S. Department of Justice
Civil Division
Office of Immigration Litigation
District Court Section
P.O. Box 868, Ben Franklin Station
Washington, D.C. 20044
Phone: [phone]
Fax: [phone]
Email: [e-mail]
Attorneys for Defendants

PUBLIC COUNSEL
MARK D. ROSENBAUM (CA SBN 59940),
pro hac vice
[e-mail]
JUDY LONDON (CA SBN 149431), pro hac
vice
[e-mail]
KATHRYN A. EIDMANN (CA SBN
268053), pro hac vice
[e-mail]
610 South Ardmore Avenue
Los Angeles, CA 90005
Telephone: [phone]
Facsimile: [phone]
GIBSON, DUNN & CRUTCHER LLP
THEODORE J. BOUTROUS, JR. (CA SBN
132099), pro hac vice
[e-mail]
KATHERINE M. MARQUART (CA SBN
248043), pro hac vice
[e-mail]
/s/ Nathaniel L. Bach (with permission)
NATHANIEL L. BACH (CA SBN 246518),
pro hac vice
[e-mail]
333 South Grand Avenue
STIPULATION TO EXTEND TIME FOR DEFENDANTS
TO RESPOND TO PLAINTIFF’S THIRD AMENDED COMPLAINT
AND ORDER

Case 2:17-cv-00218-RSM Document 146 Filed 06/05/19 Page 4 of 4

Los Angeles, CA 90071-3197
Telephone: [phone]
Facsimile: [phone]
ETHAN D. DETTMER (CA SBN 196046),
pro hac vice
[e-mail]
555 Mission Street
San Francisco, CA 94105
Telephone: [phone]
Facsimile: [phone]
ERWIN CHEMERINSKY (DC SBN 289330;
IL SBN 3122596), pro hac vice
[e-mail]
University of California, Berkeley School of
Law
*Affiliation for identification purposes only
215 Boalt Hall
Berkeley, CA 94720-7200
Telephone: [phone]
Attorneys for Plaintiff

STIPULATION TO EXTEND TIME FOR DEFENDANTS
TO RESPOND TO PLAINTIFF’S THIRD AMENDED COMPLAINT
AND ORDER