Free Motion to Continue - District Court of California - California

Case 3:08-cv-01116-WQH-LSP

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Filed 09/02/2008

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KAREN P. HEWITT United States Attorney MEGAN CALLAN Assistant U.S. Attorney State of California Bar No. 230329 Office of the U.S. Attorney 880 Front Street, Room 6293 San Diego, CA 92101-8893 Telephone: (619) 557-7120 Email: [email protected] Attorneys for Defendant United States of America

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA MARGARITA RODRIGUEZ AND MARIA ) WHITE; ) ) Plaintiffs, ) ) v. ) ) ) UNITED STATES, and DOES 1 through 20, ) inclusive, ) ) Defendants. ) ___________________________________ ) Case No. 08cv1116-WQH (LSP)

JOINT MOTION TO CONTINUE DATE FOR FILING OF DEFENDANTS RESPONSIVE PLEADING

COME NOW THE PARTIES, Plaintiffs Margarita Rodriguez and Maria White, by and through counsel, James Sexton, and Defendant United States of America, by and through their counsel, Karen P. Hewitt, United States Attorney, and Megan Callan, Assistant United States Attorney, and hereby jointly move the Court to continue the date for the filing of Defendant's responsive pleading. The parties have agreed to a brief continuance of the date for the filing of Defendant's responsive pleading until September 8, 2008. The parties have not before requested any extension of time. The parties have agreed that such brief extension will not prejudice any party.

Case 3:08-cv-01116-WQH-LSP

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Filed 09/02/2008

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Therefore, the parties jointly request that the Court enter an order extending the time for Defendants to file their responsive pleading until September 8, 2008. DATED: September 2, 2008 Respectfully submitted, s/ James Sexton JAMES SEXTON Attorney for Plaintiffs 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 James Sexton to affix his electronic signature to this document.

DATED: September 2, 2008

Respectfully submitted, KAREN P. HEWITT United States Attorney s/ Megan Callan MEGAN CALLAN Assistant U.S. Attorney Attorneys for Defendants

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Case 3:08-cv-01116-WQH-LSP

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Filed 09/02/2008

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KAREN P. HEWITT United States Attorney MEGAN CALLAN Assistant U.S. Attorney California State Bar No. 230329 Office of the U.S. Attorney 880 Front Street, Room 6293 San Diego, California 92101-8893 Telephone: (619) 557-7120 [email protected] Attorney for Defendants UNITED STATES DISTRICT COURT

8 SOUTHERN DISTRICT OF CALIFORNIA 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Executed on September 2, 2008. s/Megan Callan Megan Callan on the following parties by electronically filing the foregoing with the Clerk of the District Court using its ECF System, which electronically notifies them James Sexton 3130 Bonita Road #104 Chula Vista, CA 91910 [email protected] I declare under penalty of perjury that the foregoing is true and correct. I am not a party to the above-entitled action. I have caused service of: JOINT MOTION TO CONTINUE DATE FOR FILING OF DEFENDANTS RESPONSIVE PLEADING 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. MARGARITA RODRIGUEZ AND MARIA ) WHITE; ) ) Plaintiffs, ) ) v. ) ) ) UNITED STATES, and DOES 1 through 20, ) inclusive, ) ) Defendants. ) ___________________________________ ) Case No. 08cv1116-WQH (LSP)

PROOF OF SERVICE