Opinion
Case No. CV 12-3868 MEJ
03-07-2013
MOHAMMAD ZAYAD, Plaintiff, v. GREGORY W. CHRISTIAN, et al., Defendants.
STUART F. DELERY Principal Deputy Assistant Attorney General Civil Division United States Department of Justice JEFFREY S. ROBINS Assistant Director, District Court Section Office of Immigration Litigation AARON S. GOLDSMITH Senior Litigation Counsel PATRICIA E. BRUCKNER, NYSBN 2632156 Trial Attorney Office of Immigration Litigation Attorneys for Defendants ASHWANI K. BHAKHRI, ESQ. SBN# 163521 LAW OFFICES OF ASHWANI K. BHAKHRI Attorney for Plaintiff
STUART F. DELERY
Principal Deputy Assistant Attorney General
Civil Division
United States Department of Justice
JEFFREY S. ROBINS
Assistant Director, District Court Section
Office of Immigration Litigation
AARON S. GOLDSMITH
Senior Litigation Counsel
PATRICIA E. BRUCKNER, NYSBN 2632156
Trial Attorney
Office of Immigration Litigation
Attorneys for Defendants ASHWANI K. BHAKHRI, ESQ.
SBN# 163521
LAW OFFICES OF ASHWANI K. BHAKHRI
Attorney for Plaintiff
STIPULATION FOR DISMISSAL; [PROPOSED] ORDER
Hon. Maria-Elena James
Plaintiff, by and through his attorney-of-record, and Defendants, by and through their attorneys-of-record, hereby stipulate to the following:
1. Plaintiff filed this action on or about July 24, 2012, seeking to compel Defendants to adjudicate his pending adjustment of status application. Defendants received a 60-day extension of their filing deadline to respond to the complaint, which is currently due by March 12, 2013.
2. Defendants removed Plaintiff's application from its prior adjudicatory hold, completed the adjudication of the application, and granted Plaintiff permanent residence on February 28, 2013.
3. Pursuant to Rule 41(a)(l)(ii) of the Federal Rules of Civil Procedure, the parties stipulate to the dismissal, with prejudice, of the entire action. Each party is to bear its own costs and fees, and no attorney's fees or costs under the Equal Access to Justice Act, or any other provision of law, will be sought in the above-captioned matter.
Respectfully submitted,
STUART F. DELERY
Principal Deputy Assistant Attorney General
Civil Division
United States Department of Justice
JEFFREY S. ROBINS
Assistant Director, District Court Section
Office of Immigration Litigation
AARON S. GOLDSMITH
Senior Litigation Counsel
________
PATRICIA E. BRUCKNER, NYSBN 2632156
Trial Attorney, District Court Section
Civil Division, Office of Immigration Litigation
United States Department of Justice
Attorneys for Defendants
________
I, Patricia E. Bruckner, hereby attest that I have on file all holograph signatures for any signatures indicated by a "conformed" signature (/s/) within this e-filed document.
SBN# 163521
LAW OFFICES OF ASHWANI K. BHAKHRI
Attorney for Plaintiff
ORDER
Pursuant to stipulation, IT IS SO ORDERED.
________
MARIA-ELENA JAMES
United States District Judge