1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

JOSEPH P. RUSSONIELLO, CSBN 44332

United States Attorney

JOANN M. SWANSON, CSBN 88143

Assistant United States Attorney

Chief, Civil Division

ILA C. DEISS, NY SBN 3052909

Assistant United States Attorney

450 Golden Gate Avenue, Box 36055

San Francisco, California 94102

Telephone: (415) 436-7124

FAX: (415) 436-7169

Attorneys for the United States and

Defendants Huelga and Merendino

JUAN OSUNA

Deputy Assistant Attorney General

JOSHUA E.T. BRAUNSTEIN

Assistant Director

COLIN A. KISOR

Senior Litigation Counsel

Office of Immigration Litigation

District Court Section

P.O. Box 868 Ben Franklin Station

Washington D.C., 20044

Telephone: (202) 532-4331

FAX: (202) 305-7000

Attorneys for the United States

 UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

COMMITTEE FOR IMMIGRANT

RIGHTS OF SONOMA COUNTY, et al.,

Plaintiffs,

v.

COUNTY OF SONOMA, et al.,

Defendants.

/

No. CV-08-4220-RS 

STIPULATION TO: (1) EXTEND TIME

WITHIN WHICH DEFENDANTS MUST

FILE AN ANSWER TO SECOND

AMENDED COMPLAINT; (2) EXTEND

TIME TO FILE INTERLOCUTORY

APPEAL; [PROPOSED] ORDER

The parties to this action, by and through their respective counsel of record, hereby enter the

following stipulation and request entry of a conforming order. This stipulation and concomitant

request for order is made based on Defendants’ pending motions to reconsider the March 10, 2010

Stipulation and Proposed Order

Case No. CV-08-4220 RS 

*E-Filed 5/11/10*

Case 3:08-cv-04220-RS Document 190 Filed 05/11/10 Page 1 of 3
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Order re Motions to Dismiss (Docket Numbers 174 and 177), which were heard by the Court and

taken under submission on May 6, 2010.

STIPULATION

1. Absent an intervening order, the time in which Defendants must file and serve their

answers to Plaintiffs’ Second Amended Complaint (which date is currently set for May 10, 2010) shall

be extended to a date that is 10 days after entry of the Court’s decision on the pending motions to

reconsider.

2. Absent an intervening order, the time in which the parties may file interlocutory

appeals of the March 10, 2010 Order re Motions to Dismiss, as provided in Federal Rule of Appellate

Procedure 4(a) or otherwise, is hereby extended for an additional 30 days, to June 8, 2010, pursuant to

Federal Rule of Appellate Procedure 4(a)(5). This stipulation and request for extension of the

appellate period set forth in the Federal Rules of Appellate Procedure does not prejudice or affect

other rights of the parties, including the ability of the parties to otherwise request or seek appellate

review, and is made in an abundance of caution to preserve their rights to appeal.

Respectfully submitted,

Dated: May 10, 2010 JOSEPH P. RUSSONIELLO

United States Attorney

By __________/s/_____________________

Ila C. Deiss

Assistant United States Attorney

Attorneys for Defendants U.S. Department of

Homeland Security, Bureau of Immigration and

Customs Enforcement; Agent Mario Huelga; and

Special Agent Chris Merendino

Dated: May 10, 2010 JUAN OSUNA

Deputy Assistant Attorney General, Civil Division

By________/s/_______________________

 Colin Kisor

Senior Litigation Counsel

United States Department of Justice

Office of Immigration Litigation

Attorneys for Defendant U.S. Department of

Homeland Security, Bureau of Immigration and

Customs Enforcement

Stipulation and Proposed Order

Case No. CV-08-4220 RS 2

Case 3:08-cv-04220-RS Document 190 Filed 05/11/10 Page 2 of 3
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Dated: May 10, 2010 Stephen M. Woodside, County Counsel

By _____________/s/__________________

Anne L. Keck, Deputy County Counsel

Sonoma County

BERTRAND, FOX & ELLIOT

Thomas F. Bertrand

Richard W. Osman

Dated: May 10, 2010 LATHAM WATKINS, LLP

Alfred C. Pfeiffer

Melissa N. Chan

Tienlon Ho

Mary Elizabeth-Heard

Jason Daniels

Casey R. O’Connor

By___________/s/ __________________

Alfred C. Pfeiffer, Jr.

Julia Harumi Mass

Alan L. Schlosser

AMERICAN CIVIL LIBERTIES UNION

FOUNDATION OF NORTHERN

CALIFORNIA

[PROPOSED] ORDER

Pursuant to stipulation, IT IS SO ORDERED.

Date: ___________________________________

RICHARD SEEBORG

United States District Judge

Stipulation and Proposed Order

Case No. CV-08-4220 RS 3

5/11/10

Case 3:08-cv-04220-RS Document 190 Filed 05/11/10 Page 3 of 3