Opinion
3:24-cv-04584 LJC
09-25-2024
HAMED HAFEZY, Plaintiff, v. MERRICK B. GARLAND, in his official capacity as Attorney General, United States Department of Justice, et al., Defendants.
ISMAIL J. RAMSEY United States Attorney ELIZABETH D. KURLAN Assistant United States Attorney Attorneys for Defendants ZACHARY NIGHTINGALE Van Der Hout LLP Attorney for Plaintiff
ISMAIL J. RAMSEY United States Attorney
ELIZABETH D. KURLAN Assistant United States Attorney Attorneys for Defendants
ZACHARY NIGHTINGALE Van Der Hout LLP Attorney for Plaintiff
STIPULATION TO EXTEND TIME FOR DEFENDANTS' RESPONSE TO PLAINTIFF'S COMPLAINT; AND ORDER
LISA J. CISNEROS UNITED STATES MAGISTRATE JUDGE
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.
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.
ORDER
Pursuant to stipulation, IT IS SO ORDERED.
DECLARATION OF ELIZABETH D. KURLAN
I, Elizabeth D. Kurlan, declare and state as follows:
1. I am an Assistant United States Attorney in the United States Attorney's Office for the Northern District of California and counsel of record for the federal Defendants in the above-captioned action.
2. On July 29, 2024, Plaintiff filed a complaint in which he seeks adjudication of his parents' applications for immigrant visas. See Dkt. No. 1. Our office was served with the complaint on July 31, 2024.
3. On September 9, 2024, my office contacted Plaintiff's counsel regarding Defendants' request for an extension of time to prepare their response to the complaint, and Plaintiff consented to the request.
I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct.