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

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

Document 4

Filed 01/24/2008

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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 RAFAEL VIDAL COLL HERRERA, ) ) Plaintiff, ) ) v. ) ) MICHAEL B. MUKASEY, United States ) Attorney General, et al., ) ) Defendants. ) ___________________________________ ) 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. In order to address Plaintiff's claims 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 jointly request this 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 February 25, 2008 ///

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

Document 4

Filed 01/24/2008

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Dated: January 24, 2008

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

DATED: January 24, 2008 7 8 9 Pursuant to Section 2(f)(4) of the Electronic Case Filing Administrative Policies and Procedures 10 of the United States District Court for the Southern District of California, I certify that the content of 11 this document is acceptable to counsel for the Petitioner and that I have obtained authorization from 12 Tatyana A. Edwards to affix her electronic signature to this document. 13 14 15 16 17 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: January 24, 2008 KAREN P. HEWITT United States Attorney s/ Tatyana A. Edwards TATYANA A. EDWARDS Attorney for Plaintiff

Joint Motion to Extend

07cv2217