Complaint - JOINT STIPULATION East Bay Sanctuary Covenant v. Garland, Case No. 4 (2021-03-29), Doc. 142 — East Bay Sanctuary Covenant v. Barr
- Date
- 2021-03-29
Summary
A Joint Stipulation on Scheduling filed March 24, 2021 as Document 142 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 move to dismiss or answer the Complaint is March 29, 2021, and that the parties' joint motion to stay proceedings, filed February 25, 2021 (Dkt. No. 140), remains pending. The parties agree that the deadline should be extended to 30 days from the court's ruling on the stay motion if the court denies it, and otherwise stayed with the case. The four-page filing includes a blank signature line for the district judge, signatures by Erez Reuveni of the Department of Justice for Defendants and Katrina Eiland of the American Civil Liberties Union Foundation for Plaintiffs, and a certificate of service.
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Case 4:19-cv-04073-JST Document 142 Filed 03/24/21 Page 1 of 4
SARAH HARRINGTON
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Deputy Assistant Attorney General
2 WILLIAM C. PEACHEY
Director
3 EREZ REUVENI
Assistant Director
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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
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9 UNITED STATES DISTRICT COURT
10 FOR THE NORTHERN DISTRICT OF CALIFORNIA
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12 East Bay Sanctuary Covenant, et al., )
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Plaintiffs, )
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v. ) Civil Action No. 4:19-cv-04073-JST
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16 Merrick B. Garland, et al., )
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17 Defendants. )
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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 142 Filed 03/24/21 Page 2 of 4
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 __, 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 142 Filed 03/24/21 Page 3 of 4
Dated: March 24, 2021 Respectfully submitted,
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2 By: /s/ Erez Reuveni
EREZ REUVENI
3 Assistant Director
Office of Immigration Litigation
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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
Case 4:19-cv-04073-JST Document 142 Filed 03/24/21 Page 4 of 4
1 CERTIFICATE OF SERVICE
2 I hereby certify that on March 24, 2021, I electronically filed the foregoing document with
3 the Clerk of the Court for the United States Court of for the Northern District of California by
4 using the CM/ECF system. Counsel in the case are registered CM/ECF users and service will be
5 accomplished by the CM/ECF system.
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By: /s/ Erez Reuveni
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EREZ REUVENI
8 Assistant Director
United States Department of Justice
9 Civil Division
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JOINT STIPULATION
East Bay Sanctuary Covenant v. Garland,
Case No. 4:19-cv-04073-JST
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