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Complaint - JOINT STIPULATION East Bay Sanctuary Covenant v. Garland, Case No. 4 (2021-03-29), Doc. 143 — East Bay Sanctuary Covenant v. Barr

Date
2021-03-29

Summary

A joint stipulation on scheduling filed March 24, 2021 as Document 143 in East Bay Sanctuary Covenant, et al. v. Merrick B. Garland, et al., Civil Action No. 4:19-cv-04073-JST, in the U.S. District Court for the Northern District of California. It states that the government's deadline to answer or move to dismiss the Complaint is March 29, 2021, and that the parties' joint motion to stay proceedings, filed February 25, 2021 (Dkt. No. 140), is pending. The parties stipulate that the deadline be extended to 30 days from the court's ruling if the stay is denied, and otherwise be stayed with the case. The three-page filing includes a signature line for the district judge and is signed by the Department of Justice Office of Immigration Litigation for defendants and the ACLU Foundation Immigrants' Rights Project for plaintiffs.

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Full text

                 Case 4:19-cv-04073-JST Document 143 Filed 03/24/21 Page 1 of 3




     SARAH HARRINGTON
 1
     Deputy Assistant Attorney General
 2   WILLIAM C. PEACHEY
     Director
 3   EREZ REUVENI
     Assistant Director
 4
     Office of Immigration Litigation
 5   U.S. Department of Justice, Civil Division
     P.O. Box 868, Ben Franklin Station
 6   Washington, DC 20044
 7   Tel: (202) 307-4293
     Email: Erez.R.Reuveni@usdoj.gov
 8
 9                                   UNITED STATES DISTRICT COURT
10                             FOR THE NORTHERN DISTRICT OF CALIFORNIA

11
                                                    )
12    East Bay Sanctuary Covenant, et al.,          )
13                                                  )
                         Plaintiffs,                )
14                                                  )
      v.                                            )        Civil Action No. 4:19-cv-04073-JST
15                                                  )
16    Merrick B. Garland, et al.,                   )
                                                    )
17                       Defendants.                )
                                                    )
18
19                                     JOINT STIPULATION ON SCHEDULING

20         1. The government’s deadline to file a motion to dismiss or otherwise answer the Complaint
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     is currently due March 29, 2021.
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           2. However, pending before the Court is the parties’ joint motion to stay proceedings, filed
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24   February 25, 2021 (Dkt. No. 140).

25         3. Because the motion remains pending, the parties agree that Defendants’ deadline to file a
26   motion to dismiss or other responsive pleading should be extended to thirty (30) days from the
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     date the court issues its ruling on the motion to stay, should the court decline to enter the stay.
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     JOINT STIPULATION
     East Bay Sanctuary Covenant v. Garland,
     Case No. 4:19-cv-04073-JST
                 Case 4:19-cv-04073-JST Document 143 Filed 03/24/21 Page 2 of 3




          For the reasons stated, the parties hereby STIPULATE and AGREE that Defendants’ deadline
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 2   for filing any motion to dismiss or responsive pleading shall be extended to 30 days from the date

 3   the court rules on the government’s motion to stay, in the event the court denies that motion, and
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     otherwise, shall be stayed along with the case should the court grant that motion.
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 7   Dated: March 24, 2021                                       _______________________
                                                                 United States District Judge
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     JOINT STIPULATION
     East Bay Sanctuary Covenant v. Garland,
     Case No. 4:19-cv-04073-JST
                 Case 4:19-cv-04073-JST Document 143 Filed 03/24/21 Page 3 of 3




     Dated: March 24, 2021                        Respectfully submitted,
 1
 2                                             By: /s/ Erez Reuveni
                                                  EREZ REUVENI
 3                                                Assistant Director
                                                  Office of Immigration Litigation
 4
                                                  U.S. Department of Justice, Civil Division
 5                                                P.O. Box 868, Ben Franklin Station
                                                  Washington, DC 20044
 6                                                Tel: (202) 307-4293
 7                                                Email: erez.r.reuveni@usdoj.gov

 8                                                Attorneys for Defendants
 9                                                /s/Katrina Eiland
10                                                Katrina Eiland
                                                  AMERICAN CIVIL LIBERTIES UNION
11                                                FOUNDATION
                                                  IMMIGRANTS’ RIGHTS PROJECT
12                                                39 Drumm Street
13                                                San Francisco, CA 94111
                                                  T: (415) 343-0782
14                                                F: (415) 395-0950
                                                  Email: keiland@aclu.org
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                                                  Attorneys for Plaintiffs
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     JOINT STIPULATION
     East Bay Sanctuary Covenant v. Garland,
     Case No. 4:19-cv-04073-JST


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