Free Stipulation - District Court of California - California

Case 3:07-cv-05091-EMC

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Filed 12/20/2007

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Michael Craig Cox, CA SBN # 248393 120 Roble Road, #108 Walnut Creek, CA 94597 Telephone: 650.245.2565 Facsimile: by appointment: 925.943.6249 Email: [email protected] Attorney for Petitioner Omid SAADATI

UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION

) ) ) Petitioner, ) ) v. ) ) Michael CHERTOFF, in his official capacity,) ) Secretary, United States Department of ) Homeland Security; ) Peter KEISLER, in his official capacity, Attorney General, United States Department of ) ) Justice; ) Emilio GONZALEZ, in his official capacity, ) Director, United States Citizenship and ) Immigration Services, United States ) Department of Homeland Security; and ) Gerard HEINAUER, in his official capacity, ) Director, Nebraska Service Center, United ) States Citizenship and Immigration Services, ) United States Department of Homeland ) Security, Lincoln, Nebraska ) ) ) Respondents. ) Omid SAADATI,

Case No.: C07-05091 EMC

Stipulation and [Proposed] Order Continuing Case Management Conference Immigration Case Agency No.: A071 759 726

Stipulation and Order Continuing CMC - 1

Case No.

C07-05091 EMC

Case 3:07-cv-05091-EMC

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Filed 12/20/2007

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Petitioner Saadati, by and through his attorney of record, and Respondents, by and through their attorneys of record, hereby stipulate, subject to approval of the Court, to the following:

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1. Petitioner Saadati filed a petition on October 3, 2007, asking the Court to review, de novo, Petitioner Saadati's naturalization application and grant his naturalization, or in the alternative, order the United States Citizenship and Immigration Services to adjudicate Petitioner Saadati's application for naturalization.

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2. Respondents filed an answer on December 10, 2007. 3. The Initial Case Management Conference is currently scheduled on January 16, 2008. 4. The parties believe Petitioner's case may possibly be administratively resolved within the next couple of months. 5. The parties therefore agree, subject to approval by the Court, to continue the Case Management Conference currently set for January 16, 2008 to March 19, 2008. 6. The parties further agree, subject to approval by the Court, to file a joint case

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management statement seven days in advance of the case management conference, and to file the necessary Alternative Dispute Resolution documents twenty-one days in advance of the case management conference. The parties are also discussing the propriety of discovery and, if necessary, will provide their initial disclosures and Rule 26(f) report seven days before the case management conference.

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Respectfully submitted, Dated this 14th day of December, 2007 /s/ Michael Craig Cox ___________________________ Michael Craig Cox
Stipulation and Order Continuing CMC - 2 Case No.

C07-05091 EMC

Case 3:07-cv-05091-EMC

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Attorney for Petitioner Omid Saadati Dated:

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______/s/____________________ Ila Deiss Assistant United States Attorney Attorney for Respondents ORDER PURSUANT TO STIPULATION, IT IS SO ORDERED that the Case Management Conference be continued to March 19, 2008.

Dated: ___________________________ Edward M. Chen United States Magistrate Judge

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Stipulation and Order Continuing CMC - 3

Case No.

C07-05091 EMC