Free Motion for Extension of Time to File Answer - District Court of California - California

Case 5:08-cv-01817-JF

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Filed 06/02/2008

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JOSEPH P. RUSSONIELLO (CSBN 44332) United States Attorney JOANN M. SWANSON (CSBN 88143) Chief, Civil Division MELANIE L. PROCTOR (CSBN 228971) [email protected] Assistant United States Attorney 450 Golden Gate Avenue, Box 36055 San Francisco, California 94102-3495 Telephone: (415) 436-6730 FAX: (415) 436-7169 Attorneys for Defendants

8 UNITED STATES DISTRICT COURT 9 NORTHERN DISTRICT OF CALIFORNIA 10 SAN JOSE DIVISION 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 ANA GOURKOVA, ) ) Plaintiff, ) ) v. ) ) MICHAEL MUKASEY, Attorney General ) of the United States; et al., ) ) Defendants. ) ) No. C 08-1817 JF

JOINT MOTION TO EXTEND TIME TO ANSWER; PROPOSED ORDER

Plaintiff, by and through her attorney of record, and Defendants by and through their attorneys of record, hereby stipulate, subject to the approval of the Court, to the following: 1. Plaintiff filed this action on or about April 4, 2008. Defendants' response is due on June 6, 2008. 2. Pursuant to this Court's April 4, 2008 Order Setting the Case Management Conference, the parties are required to file a joint case management statement on August 1, 2008, and attend a case management conference on August 8, 2008. 3. Further, in order to allow sufficient time for Defendants to consider an alternative resolution to this case and/or Answer and prepare a joint case management statement, the parties hereby respectfully ask this Court to modify the dates in the Court's scheduling order as follows: ///
JOINT MOTION C 08-1817 JF

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Case 5:08-cv-01817-JF

Document 3

Filed 06/02/2008

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Last day to file Defendants' Answer: Last day to file Joint ADR Certification: Last day to file/serve Joint Case Management Statement: Case Management Conference: Dated: June 2, 2008

August 1, 2008 August 8, 2008 September 5, 2008 September 12, 2008, at 10:30 a.m. Respectfully submitted, JOSEPH P. RUSSONIELLO United States Attorney /s/ MELANIE L. PROCTOR1 Assistant United States Attorney Attorneys for Defendant

Dated: June 2, 2008 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 I, Melanie L. Proctor, hereby attest that I have on file all holograph signatures for any signatures indicated by a "conformed" signature (/S/) within this efiled document.
JOINT MOTION C 08-1817 JF
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/s/ FRANK P. SPROULS Attorney for Plaintiff PROPOSED ORDER Pursuant to stipulation, IT IS SO ORDERED. Dated: JEREMY FOGEL United States District Judge

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