IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA
September 11, 2012
UNITED STATES DEPARTMENT OF HOMELAND SECURITY AND DOES 1-50, DEFENDANTS.
The opinion of the court was delivered by: Sheila K. Oberto United States Magistrate Judge
DEFENDANT'S EX PARTE APPLICATION FOR INITIAL 65-DAY EXTENSION OF TIME TO RESPOND TO COMPLAINT; ORDER
The U.S. Department of Homeland Security, defendant, applies under Local Rule 144(c) for an initial 65-day extension of the time under Fed. R. Civ. P. 12(a)(2) for defendant's response to the complaint. The reason is that defense counsel needs more time to confer with the various concerned offices including the parts of Homeland Security's Office of Principal Legal Advisor that deal with Federal Tort Claims Act and the Privacy Act, two regional law offices in the Bureau of Prisons, this office's Criminal Division, and the DOJ Civil Division's Federal Programs Branch and Office of Immigration Litigation, to formulate defendant's position, to write a responsive motion, and to obtain internal review of the motion before filing. Scheduling constraints are explained in the accompanying counsel declaration. No previous extension of this time has been requested or granted. A suggested form of order is included in the event this application is granted.
Dated: September 11, 2012 BENJAMIN B. WAGNER United States Attorney By: /s/ YHimel YOSHINORI H. T. HIMEL Assistant U.S. Attorney
Upon defendant's ex parte application, good cause having been shown, defendant's time to respond to the complaint is extended until November 21, 2012.
IT IS SO ORDERED.
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