Free Motion to Continue - District Court of California - California

Case 3:08-cv-00501-DMS-POR

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Filed 07/29/2008

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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] Counsel for Defendants

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA DELFINA GIL DE CARREON, ENRIQUE) EVELIO CARREON, ) ) Plaintiffs, ) v. ) ) MICHAEL B. MUKASEY, Attorney) General of the United States; MICHAEL) CHERTOFF, Secretary, Department of) Homeland Security (DHS); and EMILIO T.) GONZALEZ, Director, United States) Citizenship and Immigration Services.) ) Defendants. ) __________________________________) Case No. 08cv0501 DMS (POR) JOINT MOTION TO CONTINUE HEARING AND RESPONSE AND REPLY DATES FOR DEFENDANTS' MOTION TO DISMISS DATE: August 22, 2008 TIME: 1:30 p.m. CTRM: 10 Honorable Dana M. Sabraw

COME NOW THE PARTIES, Plaintiffs Delfina Gil de Carreon and Enrique Evelio Carreon, by and through counsel, Murray Hilts and Michael Codner, and Defendants Michael Chertoff, et al., by and through their counsel, Karen P. Hewitt, United States Attorney, and Caroline Clark, Assistant United States Attorney, and hereby jointly move the Court to continue the hearing date for the Defendants' Motion to Dismiss, currently scheduled for August 22, 2008, at 1:30 p.m., until September 5, 2008, at 1:30 p.m. The parties further request that the time for filing Plaintiff's response and Defendants' reply pursuant to Civil Local Rule 7.1(e) be continued and calculated according to the new hearing date. The request is made due to an issue that has arisen affecting the availability of counsel for Defendants on August 22, 2008. Based upon the foregoing, it is respectfully requested that the Court

Case 3:08-cv-00501-DMS-POR

Document 10

Filed 07/29/2008

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enter an order continuing the August 22, 2008, hearing and the accompanying response and reply deadlines.

DATED: July 29, 2008

s/ Michael J. Codner MICHAEL J. CODNER Counsel 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 Michael Codner to affix his electronic signature to this document.

DATED: July 29, 2008

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

14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2 CAROLINE J. CLARK Assistant United States Attorney Counsel for Defendants E-Mail: [email protected]

08cv0501