Free Motion for Extension of Time to File Response/Reply - District Court of California - California

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

Document 6

Filed 02/21/2008

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KAREN P. HEWITT United States Attorney RAVEN M. NORRIS Assistant U.S. Attorney California State Bar No. 232868 880 Front Street, Room 6293 San Diego, California 92101-8893 Telephone: (619) 557-7157 Facsimile: (619) 557-5004 Attorneys for the Defendants TATYANA A. EDWARDS California State Bar No. 201808 Law Offices of Tatyana A. Edwards, APC 402 W. Broadway, Suite 720 San Diego, California 92101 Attorneys for Plaintiff UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA ) ) Plaintiff, ) ) v. ) ) MICHAEL B. MUKASEY, United States ) Attorney General, et al., ) ) Defendants. ) ___________________________________ ) RAFAEL VIDAL COLL HERRERA, Case No. 07cv 2217 -JAH (WMC) JOINT MOTION TO EXTEND TIME FOR FILING OF RESPONSIVE PLEADING [Fed. R. Civ. P. 6(b)(1)]

COME NOW THE PARTIES, Plaintiff Rafael Vidal Coll Herrera, by and through his counsel, Law Office of Tatyana A. Edwards, and Defendants Michael B. Mukasey, et al., by and through their counsel, Karen P. Hewitt, United States Attorney, and Raven M. Norris, Assistant United States Attorney, hereby jointly move the Court to extend the time for filing of Defendants' responsive pleading. The parties are working toward an extrajudicial resolution of Plaintiff's complaint, and the parties have agreed that additional time is required before Defendants' filing of any responsive pleading in order to pursue resolution of Plaintiff's claims without the intervention of the Court. In an effort to resolve Plaintiff's complaints and without waiving Defendants' rights to defend the causes of actions and allegations, including the right to file any Fed. R. Civ. P. 12 motions to dismiss, the parties now jointly request this extension of time. Accordingly, the parties jointly request that the Court extend the date upon which Defendants' responsive pleadings are due until

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

Document 6

Filed 02/21/2008

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March 25, 2008. The parties have previously requested one extension of time. Based upon the foregoing, it is respectfully requested that the Court enter an order, under Fed. R. Civ. P. 6(b)(1), expanding the time for the filing of Defendants' responsive pleading until March 25, 2008.

Dated: February 21, 2008

Respectfully submitted, KAREN P. HEWITT United States Attorney s/ Raven M. Norris RAVEN M. NORRIS Assistant U.S. Attorney Attorneys for Defendants

DATED: February 21, 2008 12 13 14 Pursuant to Section 2(f)(4) of the Electronic Case Filing Administrative Policies and Procedures 15 of the United States District Court for the Southern District of California, I certify that the content of 16 this document is acceptable to counsel for the Petitioner and that I have obtained authorization from 17 Tatyana A. Edwards to affix her electronic signature to this document. 18 19 20 21 22 23 24 25 26 27 28 2 s/Raven M. Norris Assistant U. S. Attorney Attorney for Defendants Email: [email protected] DATED: February 20, 2008 KAREN P. HEWITT United States Attorney s/ Tatyana A. Edwards TATYANA A. EDWARDS Attorney for Plaintiff

Joint Motion to Extend

07cv2217

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

Document 6

Filed 02/21/2008

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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA ) ) ) Plaintiff, v. ) ) MICHAEL B. MUKASEY, Attorney General,) Department of Justice, et al., ) ) ) Defendants. _____________________________________ ) IT IS HEREBY CERTIFIED THAT: I, Raven M. Norris, 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. I am not a party to the above-entitled action. I have caused service of the Joint Motion to Extend Time To File Responsive Pleading on the following parties by electronically filing the foregoing with the Clerk of the District Court using its ECF System, which electronically notifies them. Tatyana A. Edwards, Esq. RAFAEL VIDAL COLL HERRERA, Case No. 07cv2217 JAH (WMc) CERTIFICATE OF SERVICE

14 15 16 17 18 I declare under penalty of perjury that the foregoing is true and correct. 19 Executed on February 21, 2008 20 21 22 23 24 25 26 27 28 3 s/ Raven M. Norris RAVEN M. NORRIS 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: None the last known address, at which place there is delivery service of mail from the United States Postal Service.

Joint Motion to Extend

07cv2217