Case :0-cv-0-TJH-CT Document Filed //0 Page of 0 AHlLAN T. ARULANANTHAM, SBN MARK D. ROSENBAUM SBN 0 ACLU FOUNDATION OF SOUTHERN CALIFORNIA Beverly Boulevard Los Angeles CA 00- Telephone: () -00 FaCSImile: () 0- BRADLEY S. PHILLIPS SBN STEPHEN M. KRISTOVICH SBN FRED A. ROWLEY, JR. SBN FADIA RAFEEDIE KHOURY SBN 0 ORIGINAL Il CLERK U.S. DISTRICT COURT c_:trm ~mrro;mll WESLEY T. SHIH SBN BY DfPU~ MUNGER, TOLLES & OLSON LLP South Grand Avenue Thirty-Fifth Floor Los Angeles CA 00-0 Telephone: () -00 Facsnnie: () -0 Attorneys for Plaintiffs AMADOU LAMINE DIOUF! RAYMOND SOEOTH, individually and on behalf of all others similarly situated, vs. UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA Plaintiffs, CASE NO. CV0- priority end Enter - Closed - J-/J- - J-/J- - canony- CTx) JOINT STIPULATION ND ORDER REUESTING STAY OF ALL PR CEEDINGS o.. I ~. J, ). - JOHN OF,j OFEICE AND REMO\l=AL ANTHONY TANGEMAN FORMER DIRECTOR
Case :0-cv-0-TJH-CT Document Filed //0 Page of OF ICE OFFICE OF DETENTION AND REMOVAL, JOHN DOES -0 (FEDERAL OFFICIALS WITHIN THE DEPARTMENT OF HOMELAND SECURITY AND DIVISION OF IMMIGRATION HEALTH SERVICES);.,. JEFFRY BRINKLEY JOHN DuE (A PHYSIciAN), MARK PORTER JOHN DOE (AN ICE OFFICER), JOHN DOES - (FEDERAL OFFICIALS WITHIN THE DIVISION OFIMMIGRATIONHEALTH SERVICES) Defendants. II------------------------~ 0
Case :0-cv-0-TJH-CT Document Filed //0 Page of I I I i. JOINT STIPULATION AND ORDER REQUESTING STAY OF ALL PROCEEDINGS The parties hereby jointly request that this Court stay all litigation in this case, including all briefing deadlines and discovery obligations, from November, 0 until December,0. lfthe parties wish to continue the stay beyond that date, they will inform the Court by separate filing. The parties are filing this joint stipulation because they have entered into an agreement that is memorialized in correspondence dated November, 0. The agreement includes a requirement that the parties engage in good-faith mediation in an attempt to resolve all claims in 0 this case. It is so stipulated. Dated: November, 0 Dated: November,0 ACLU OF SOUTHERN CALIFORNIA MUNGER, TOLLES & OLSEN, LLP /'uv~ AHILAN T. ARULANANT~ Attorneys for Plaintiffs JEFFREY S. BUCHOLTZ. Assistant Attorney General, Civil Division THOMAS P. O'BRIEN United States Attorne:y ROBERT. LESTER Assistant United States Attorney DAVID J. KLINE Principal Deputy Director GJONJUNCAJ T 'alatto ey 't rial tt ey Office Immigration Litigation. Attorneys for Defend,ants
Case :0-cv-0-TJH-CT Document Filed //0 Page of lo IT IS SO ORDERED. Dated: November -,0 HONORABLE TERRY J. HATTER United States District Judge
Case :0-cv-0-TJH-CT Document Filed //0 Page of 0 PROOF OF SERVICE STATE OF CALIFORNIA, COUNTY OF LOS ANGELES I am employed in the County of Los Angeles, State of California. I am over the age of and not a party to the within action. My business address is Beverly Boulevard, Los Angeles, California 00. I am employed in the office of a member of the bar of this court at whose direction the service was made. On November, 0November, 0, I served the foregoing document: JOINT STIPULATION AND ORDER REQUESTING STAY OF ALL PROCEEDINGS on the parties in this action by placing a true and correct copy of each document thereof, enclosed in a sealed envelope, addressed as follows: Sheri Glaser U.S. Department of Justice th Street, NW National Press Building Room - Washington, DC 0 Email: sheri.glaser@usdoj.gov GjonJuncaj U.S. Department ofjustice P.O. Box, Ben Franklin Station Washington, DC 0 Email: gjonjuncaj@usdoj.gov Arthur Rizer U.S. Department of Justice Office ofimmigration Litigation P.O. Box, Ben Franklin Station Washington, DC 0 Email: arthur.rizer@usdoj.gov
Case :0-cv-0-TJH-CT Document Filed //0 Page of l 0 C. Barrington Wilkins U.S. Department of Justice P.O. Box, Ben Franklin Station Washington, DC 0 Email: c.barrington. wilkins@usdoj.gov Mary H. Mason Civil Division, Torts Branch Constitutional Tort Litigation Section P.O. Box Washington, D.C. 0 Email: mary.mason@usdoj.gov Edward J. Martin Civil Division, Torts Branch Constitutional Tort Litigation Section P.O. Box Washington, D.C. 0 Email: edward.martin@usdoj.gov Robert I. Lester Office of the U.S. Attorney 00 North Los Angeles Street Los Angeles, CA 00 Email: Robert.Lester@usdoj.gov I am readily familiar with the business' practice of collection and processing correspondence for mailing with the United States Postal Service. I know that the correspondence is deposited with the United States Postal Service on the same day this declaration was executed in the ordinary course of business. I know that the envelope was sealed and, with postage thereon fully prepaid, placed for collection and mailing on this date, following ordinary business practices, in the United States mail at Los Angeles, California. Executed on November, 0, at Los Angeles, California. ~ / Geneva Tien