Free Motion to Dismiss - District Court of California - California

Case 3:08-cv-01028-WQH-NLS

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Filed 07/21/2008

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KAREN P. HEWITT United States Attorney CAROLINE J. CLARK Assistant U.S. Attorney California State Bar No. 220000 Office of the U.S. Attorney 880 Front Street, Room 6293 San Diego, California 92101-8893 Telephone: (619) 557-7491 Facsimile: (619) 557-5004 E-mail: [email protected]

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA

SAAD ALI GHULAM,

) ) Plaintiff, ) ) v. ) ) PAUL PIERRE, Director, San Diego) District Office, U.S. Citizenship and) Immigration Services; MICHAEL) CHERTOFF, U.S. Secretary of Homeland) Security; and MICHAEL MUKASEY, U.S.) Attorney General, ) ) Defendants. ) __________________________________ )

Case No. 08cv1028 WQH (NLS)

JOINT MOTION TO DISMISS COMPLAINT

COME NOW THE PARTIES, Plaintiff Saad Ali Ghulam, by and through counsel, Alan M. Anzarouth, and Defendants Paul Pierre, et al., by and through their counsel, Karen P. Hewitt, United States Attorney, and Caroline J. Clark, Assistant United States Attorney, and hereby jointly move the Court to dismiss this complaint as moot. The parties have resolved the matters alleged in Plaintiff's complaint as Defendant USCIS has adjudicated Plaintiff's application for adjustment of status. The parties agreed that the above-captioned case would be dismissed in its entirety. The parties further agreed that each party will bear its own fees and costs of suit. ///

Case 3:08-cv-01028-WQH-NLS

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Filed 07/21/2008

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Therefore, the parties respectfully request that the Court enter an order dismissing the complaint as moot.

DATED: July 21, 2008

s/ Alan M. Anzarouth _______________________ ALAN M. ANZAROUTH Attorney for Plaintiff E-Mail: [email protected]

Pursuant to Section 2(f)(4) of the Electronic Case Filing Administrative Policies and Procedures of the United States District Court for the Southern District of California, I certify that the content of this document is acceptable to counsel for the Plaintiff and that I have obtained authorization from Alan M. Anzarouth to affix his electronic signature to this document.

DATED: July 21, 2008

KAREN P. HEWITT United States Attorney s/ Caroline J. Clark

15 16 17 18 19 20 21 22 23 24 25 26 27 28 2 CAROLINE J. CLARK Assistant United States Attorney Attorneys for Defendants E-Mail: [email protected]

08cv1028

Case 3:08-cv-01028-WQH-NLS

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Filed 07/21/2008

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KAREN P. HEWITT United States Attorney CAROLINE J. CLARK Assistant U.S. Attorney California State Bar No. 220000 Office of the U.S. Attorney 880 Front Street, Room 6293 San Diego, California 92101-8893 Telephone: (619) 557-7491 Facsimile: (619) 557-5004 E-mail: [email protected]

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA SAAD ALI GHULAM, ) ) Plaintiff, ) ) v. ) ) PAUL PIERRE, Director, San Diego) District Office, U.S. Citizenship and) Immigration Services; MICHAEL) CHERTOFF, U.S. Secretary of Homeland) Security; and MICHAEL MUKASEY, U.S.) Attorney General, ) ) 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 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: JOINT MOTION TO DISMISS COMPLAINT on the following party by electronically filing the foregoing with the Clerk of the District Court using its ECF System, which electronically provides notice. Alan M. Anzarouth, Esq. Attorney for Plaintiff E-Mail: [email protected] I declare under penalty of perjury that the foregoing is true and correct. Executed on July 21, 2008. s/ Caroline J. Clark Caroline J. Clark Case No. 08cv1028 WQH (NLS)

CERTIFICATE OF SERVICE