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United States of America v. Safee Ayub Salama

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA


June 23, 2011

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

The opinion of the court was delivered by: Oliver W. Wanger United States District Judge

TONY WEST H. TY KHARAZI Assistant Attorney General Yarra, Kharazi & Associates J. MAX WEINTRAUB 1250 Fulton Mall, Suite 202 Senior Litigation Counsel Fresno, CA 93721 KIRSTEN L. DAEUBLER Tel: (559) 441-1214 Trial Attorney Fax: (559) 441-1215 United States Department of Justice E-mail: tkharazi@yahoo.com Civil Division SBN 187894 Office of Immigration Litigation District Court Section Attorney for Defendant P.O. Box 868, Ben Franklin Station Washington, DC 20044 Tel: (202) 616-4458 Fax: (202) 305-7000 E-mail: Kirsten.Daeubler@usdoj.gov Attorneys for Plaintiff

Stipulation and Order Re: Amended Complaint to Revoke Naturalization

This is an action to revoke and set aside the order admitting Defendant Safee Ayub Salama to United States citizenship and to cancel his certificate of naturalization. In accordance with Federal Rule of Civil Procedure 15(a), the United States seeks to file an amended complaint in this matter to correct some language in the allegations contained in the original complaint and to add new allegations and grounds for denaturalization based on evidence of marriage fraud that recently came to the attention of the United States. The Amended Complaint to Revoke Naturalization (and the accompanying exhibit thereto) are attached as "Exhibit 1."

Counsel for Defendant Salama consents to permitting the United States to file the attached amended complaint.

Respectfully submitted,

ORDER

Pursuant to this Joint Stipulation and for the reasons stated therein, IT IS HEREBY

ORDERED that the United States shall electronically file the Amended Complaint to Revoke Naturalization (attached as "Exhibit 1").

IT IS SO ORDERED.

20110623

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