Free Motion for Extension of Time to File Answer - District Court of California - California

Case 3:07-cv-02411-JAH-JMA

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Filed 02/19/2008

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KAREN P. HEWITT United States Attorney MEGAN CALLAN Assistant U.S. Attorney California Bar No. 230329 United States Attorney's Office 880 Front Street, Room 6293 San Diego, California 92101-8893 Telephone: (619) 557-7120 Facsimile: (619) 557-5004 E-mail: [email protected] Attorneys for Defendants UNITED STATES DISTRICT COURT

9 SOUTHERN DISTRICT OF CALIFORNIA 10 11 FARAMARZ RASSOULI, ZAHRA ) 12 RASSOULI, AND POUYA RASSOULI, ) ) 13 Plaintiffs, ) ) 14 v. ) ) 15 MICHAEL CHERTOFF, Secretary of U.S. ) Department of Homeland Security; et al., ) 16 ) Defendants. ) 17 ___________________________________ ) 18 Case No. 07cv2411-JAH (JMA) JOINT MOTION TO EXTEND TIME TO ANSWER [FED. R. CIV. P. 6(b)(1)]

COME NOW THE PARTIES, Plaintiffs Faramarz Rassouli, Zahra Rassouli, and Pouya Rassouli,

19 by and through counsel, Robert A. Mautino, and Defendants Michael Chertoff, et al., by and through 20 their counsel, Karen P. Hewitt, United States Attorney, and Megan Callan, Assistant United States 21 Attorney, and hereby jointly move the Court to extend the time for Defendants to answer Plaintiffs' 22 Complaint. 23 The parties are working toward an extrajudicial resolution of Plaintiffs' complaint, and the parties

24 have agreed that additional time is necessary in order to pursue resolution of Plaintiffs' claims without 25 intervention of the Court. Without waiving Defendants' rights to defend the causes of actions and 26 allegations, the parties jointly agreed to request this continuance. The parties have not previously 27 requested such continuance. 28 //

Case 3:07-cv-02411-JAH-JMA

Document 3

Filed 02/19/2008

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Based upon the foregoing, it is respectfully requested that the Court enter an order, under

2 FED. R. CIV. P. 6(b)(1), extending the time for Defendants to file their answer to Plaintiffs' Complaint 3 until May 19, 2008. 4 5 6 7 8 Pursuant to Section 2(f)(4) of the Electronic Case Filing Administrative Policies and Procedures 9 of the United States District Court for the Southern District of California, I certify that the content of this 10 document is acceptable to counsel for the Plaintiff and that I have obtained authorization from Robert 11 A. Mautino to affix his electronic signature to this document. 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2 s/ Megan Callan MEGAN CALLAN Assistant U.S. Attorney Attorneys for Defendants DATED: February 19, 2008 KAREN P. HEWITT United States Attorney DATED: February 19, 2008 Respectfully submitted, s/ Robert A. Mautino ROBERT A. MAUTINO Attorney for Plaintiff E-mail: [email protected]

Joint Motion to Extend

07cv2411

Case 3:07-cv-02411-JAH-JMA

Document 3

Filed 02/19/2008

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1 KAREN P. HEWITT United States Attorney 2 MEGAN CALLAN Assistant U.S. Attorney 3 California Bar No. 230329 United States Attorney's Office 4 880 Front Street, Room 6293 San Diego, California 92101-8893 5 Telephone: (619) 557-7120 Facsimile: (619) 557-5004 6 E-mail: [email protected] 7 Attorneys for Defendants 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 11 FARAMARZ RASSOULI, ZAHRA ) 12 RASSOULI, AND POUYA RASSOULI, ) ) 13 Plaintiff, ) ) 14 v. ) ) 15 MICHAEL CHERTOFF, Secretary of U.S. ) Department of Homeland Security; et al., ) 16 ) Defendants. ) 17 ___________________________________ ) 18 IT IS HEREBY CERTIFIED THAT: 19 20 I am not a party to the above-entitled action. I have caused service of: JOINT MOTION TO 21 EXTEND TIME TO ANSWER on the following party by electronically filing the foregoing with the Clerk of the District Court using its ECF System, which electronically provides notice. 22 Robert A. Mautino 23 Attorney for Plaintiff [email protected] 24 I declare under penalty of perjury that the foregoing is true and correct. 25 Executed on February 19, 2008. 26 s/ Megan Callan Megan Callan 27 28 3 I, the undersigned, am a citizen of the United States and am at least eighteen years of age. My business address is 880 Front Street, Room 6293, San Diego, California 92101-8893. Case No. 07cv2411-JAH (JMA) CERTIFICATE OF SERVICE

Joint Motion to Extend

07cv2411