Free Motion to Dismiss - District Court of California - California

Case 3:08-cv-01131-DMS-BLM

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Filed 07/18/2008

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The Law Offices of Robert Nadalin P.O. Box 124594 San Diego, CA 92112 (619) 234-8875 Robert G. Nadalin, Esq. Cal. State Bar No. 222489 Attorney for Ms. Roshni Sundaram UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA | | Plaintiff, | | v. | | Michael Chertoff, Secretary, | Department of Homeland Security, | et al. | | Defendants. | ____________________________________| Roshni Sundaram, Civil No. 08cv1131 DMS BLM Agency No. A95 583 083 MOTION FOR VOLUNTARY DISMISSAL OF SUIT

Roshni Sundaram, by and through her attorney of record, Robert G. Nadalin, Esq., hereby files this motion for voluntary dismissal of his complaint without prejudice pursuant to Federal Rule of Civil Procedure 41. Ms. Sundaram sought relief from this court because of an unreasonable delay in the

20 21 22 23 24 25 26 27 28 adjudication of an application for adjustment of status to lawful permanent residence. That case has now been approved and Ms. Sundaram is now in possession of her lawful permanent resident card. Therefore, this matter has become moot and Ms. Sundaram now moves for voluntary dismissal, without prejudice, of her complaint. DATED: July 18, 2008 Respectfully submitted, s/ Robert G. Nadalin ________________________ Robert G. Nadalin, Esq. Attorney for Roshni Sundaram

Case 3:08-cv-01131-DMS-BLM

Document 3-2

Filed 07/18/2008

Page 1 of 1

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The Law Offices of Robert Nadalin P.O. Box 124594 San Diego, CA 92112 (619) 234-8875 Robert G. Nadalin, Esq. Cal. State Bar No. 222489 Attorney for Ms. Roshni Sundaram UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA | Civil No. 08cv1131 DMS BLM | Plaintiff, | | Agency No. A95 583 083 | v. | PROOF OF SERVICE | Michael Chertoff, Secretary, | Department of Homeland Security, | et al. | | Defendants. | ____________________________________| Roshni Sundaram,

I, Robert G. Nadalin, attorney for Ms. Roshni Sundaram, Plaintiff in this action, a citizen of the United States over the age of eighteen years and a resident of San Diego County, California with business street address being 110 West C St., Suite 1300, San Diego, California 92101, and postal address as noted above, and not a party to the above-entitled action, hereby certify that on March 10, 2008, I caused to be served a copy of the: MOTION FOR VOLUNTARY DISMISSAL OF SUIT. by electronic filing the foregoing with the Clerk of the District Court using its ECF System, which electronically notifies them. Megan Callan Esq. Counsel for Defendants [email protected] I declare under penalty of perjury that the foregoing is true and correct. Executed on July 18, 2008 s/Robert G. Nadalin Attorney for Plaintiff E-mail: [email protected]