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United States of America v. Safee Ayub Salama

June 23, 2011

UNITED STATES OF AMERICA, PLAINTIFF,
v.
SAFEE AYUB SALAMA, DEFENDANT.



The opinion of the court was delivered by: Judge: Oliver W. Wanger, U.S. District Judge

H. Ty Kharazi, SBN 187894 YARRA, KHARAZI & ASSOCIATES 1250 Fulton Mall Fresno, CA 93721 Telephone: (559) 441-1214 Facsimile: (559) 441-1215 Attorneys for Defendant, SAFEE AYUB SALAMA

STIPULATION TO CONTINUE SCHEDULING CONFERENCE AND ORDER

Date: July 14, 2011 Time: 8:15 a.m. Crtm: 3

PLAINTIFF UNITED STATES OF AMERICA through their attorney of record, KIRSTEN L. DAEUBLER and DEFENDANT SAFEE AYUB SALAMA through his attorney of record, H. TY KHARAZI hereby stipulate to vacate and continue the Scheduling Conference as follows:

Plaintiff intends to file and has filed a First Amended Complaint to Revoke Naturalization in this action. Defendant has consented to permitting Plaintiff to file the amended complaint; a stipulation to Amend Complaint has been filed. The First Amended Complaint was filed and electronically served on Defendant's counsel on June 22, 2011.

Defendant's counsel has yet to study the First Amended Complaint and therefore, he is not in a position to anticipate the issues raised in this amended complaint, formulate a discovery plan and anticipate a trial length. Thus, parties believe that a scheduling conference in the above date may be premature at this time.

Parties, jointly respectfully request that the court continue the current Scheduling Conference 60 to 90 days. This time will allow Defendant to respond to the Amended Complaint and the parties 3 to formulate a discovery plan.

Plaintiff's counsel is respectfully requesting that she would be allowed to appear by telephone because her office is in Washington DC. Defendant has no objection to the telephonic 6 appearance by the plaintiff's counsel at the scheduling conference.

ORDER

Based on the forgoing, the Scheduling Conference currently set for July 14, 2011 shall be vacated and reset as follows:

Date: September 30, 2011

Time: 8:15AM

Department: 3

A Joint Scheduling Conference Statement must be electronically filed 7 days before the hearing date and shall be emailed, in WordPerfect or Word ...


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