Free Notice of Voluntary Dismissal - District Court of California - California

Case 3:07-cv-02217-JAH-WMC

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Tatyana A. Edwards, Esq. California State Bar No. 201808 Law Offices of Tatyana A. Edwards, APC 402 W. Broadway, Suite 720 San Diego, CA 92101 Tel: (619) 699-5875 Fax: (619) 231-1775 Email: [email protected]
Counsel for Plaintiff

IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA

RAFAEL VIDAL COLL-HERRERA,

) ) Plaintiff, ) ) v. ) ) MICHAEL B. MUKASEY, Attorney ) General, United States Department of ) Justice; MICHAEL CHERTOFF, ) Secretary of the United States Department ) of Homeland Security; and PAUL M. ) PIERRE, District Director, ) United States Citizenship and Immigration ) Services, San Diego, California, ) ) Defendants. ) ____________________________________)

Case No. 07CV 2217 JAH (WMc)

NOTICE OF VOLUNTARY DISMISSAL

NOTICE OF VOLUNTARY DISMISSAL OF PLAINTIFF'S COMPLAINT FOR WRIT OF MANDAMUS COMES NOW Plaintiff RAFAEL COO-HERRERA, by and through his counsel, LAW OFFICES OF TATYANA A. EDWARDS, APC, and respectfully moves the Court to voluntary withdraw his Complaint for Writ of Mandamus based on the following:

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Case 3:07-cv-02217-JAH-WMC

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We have received a final determination in this matter from the Department of Homeland Security, a Defendant in this action, granting Plaintiff's application for adjustment of status. Based on this information Plaintiff has informed this counsel that he wants to voluntarily withdraw the Complaint of Writ of Mandamus, filed with the Court on November 20, 2007. Accordingly Plaintiff moves the Court to withdraw his Complaint and dismiss this cause of action.

DATED: February 28, 2008
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Respectfully submitted,

s/Tatyana A. Edwards____________ Counsel for Plaintiff E-mail: [email protected]

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Tatyana A. Edwards, Esq. California State Bar No. 201808 Law Offices of Tatyana A. Edwards, APC 402 W. Broadway, Suite 720 San Diego, CA 92101 Tel: (619) 699-5875 Fax: (619) 231-1775 Email: [email protected]
Counsel for Plaintiff

IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA ) ) Plaintiff, ) ) v. ) ) MICHAEL B. MUKASEY, Attorney ) General, United States Department of ) Justice; MICHAEL CHERTOFF, ) Secretary of the United States Department ) of Homeland Security; and PAUL M. ) PIERRE, Acting District Director, ) United States Citizenship and Immigration ) Services, San Diego, California, ) ) Defendants. ) ____________________________________) IT IS HEREBY CERTIFIED THAT: I, the undersigned, am a citizen of the United States and am at least eighteen years of age. My business address is 402 W. Broadway, Suite 720, San Diego, California 92101-8893. I am not a party to the above-entitled action. I have caused service of: NOTICE OF VOLUNTARY DISMISSAL OF A COMPLAINT FOR A WRIT OF MANDAMUS on the following party by electronically filing the foregoing with the clerk of the District Court using its ECF System, which electronically provides notice.
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RAFAEL VIDAL COLL-HERRERA,

Case No. 07CV 2217 JAH (WMc)

CERTIFICATE OF SERVICE

Case 3:07-cv-02217-JAH-WMC

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Raven M. Norris Assistant U.S. Attorney Counsel for Defendants E-Mail: [email protected] I hereby certify that I have caused to be mailed the foregoing by the United States Postal Service to the following non-ECF participants on this case: MICHAEL B. MUKASEY, Attorney General United States Department of Justice C/o Office of the General Counsel U.S. Department of Homeland Security Washington, D.C. 20528 MICHAEL CHERTOFF, Secretary United States Department of Homeland Security C/o Office of the General Counsel U.S. Department of Homeland Security Washington, D.C. 20528 PAUL M. PIERRE United States Citizenship and Immigration Services C/o Office of the General Counsel U.S. Department of Homeland Security Washington, D.C. 20528 I declare under penalty of perjury that the foregoing is true and correct. Executed on February 28, 2008 at San Diego, California.

s/Tatyana A. Edwards______ Tatyana A. Edwards

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