MELINDA HAAG (CSBN 132612) United States Attorney ALEX G. TSE (CSBN 152348) Chief, Civil Division JENNIFER S. WANG (CSBN 233155) Assistant United States Attorney San Francisco, California, Attorneys for Federal Defendants
JESSICA KARP (CA BAR NO. 277347) UC Irvine Immigrant Rights Clinic c/o National Day Laborer Organizing Network, Los Angeles, CA, Attorneys for Plaintiff Asian Law Caucus
STIPULATION TO EXTEND DEADLINES FOR DISPOSITIVE MOTIONS
SAUNDRA BROWN ARMSTRONG, District Judge.
The parties by and through their counsel of record, hereby stipulate and agree as follows:
1. On August 30, 2013, the Court set the following briefing schedule for summary judgment in the above-captioned case:
Plaintiff's motion for summary judgment due: December 10, 2013
Defendants' consolidated opposition/cross-motion for summary judgment due: January 7, 2014
Plaintiff's consolidated reply/opposition to defendants' cross-motion for summary judgment due: January 21, 2014
Defendants' reply in support of cross-motion for summary judgment due: January 28, 2014
Hearing on parties' cross-motions for summary judgment: February 25, 2014 at 1:00 p.m.
2. The federal government shutdown from October 1 through October 16, 2013 has delayed defendant U.S. Immigration and Customs Enforcement's (hereinafter, "ICE") expected production of documents in response to the Freedom of Information Act ("FOIA") requests at issue. During the lapse in government appropriations, undersigned counsel for the defendant as well as ICE employees involved in the processing of the agency's response to the FOIA requests at issue were furloughed.
3. The parties believe that ICE's document production will dispose of the issues in this case, or narrow the issues for summary judgment. Accordingly, to allow ICE sufficient time to complete its production of documents prior to the deadlines for the parties' cross-motions for summary judgment, the parties respectfully request that the dispositive motions schedule be extend as follows:
Plaintiff's motion for summary judgment due: February 18, 2014
Defendants' consolidated opposition/cross-motion for summary judgment ...