United States of America v. Salama
Filing
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STIPULATION to Continue Scheduling Conference and ORDER, signed by Judge Oliver W. Wanger on 6/23/2011. (Initial Scheduling Conference previously set for 7/14/2011 has been CONTINUED to 9/30/2011 at 08:15 AM in Courtroom 3 (OWW) before Judge Oliver W. Wanger. A Joint Scheduling Conference Statement must be electronically filed 7 days before the hearing date and shall be emailed, in WordPerfect or Word format, to owworders@caed.uscourts.gov.The parties may appear telephonically. Parties are directed to set up a conference call (either through the operator or on an internal phone system). After all parties appearing telephonically are on one line, call Judge Wanger's chambers at (559) 499-5650 at the time of the hering. Courtroom Deputy Renee Gaumnitz shall be advised by email, rgaumnitz@caed.uscourts.gov, who will be appearing telephonically and provided a contact number of the party who is initiating the conference call.) (Gaumnitz, R)
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H. Ty Kharazi, SBN 187894
YARRA, KHARAZI & ASSOCIATES
1250 Fulton Mall
Fresno, CA 93721
Telephone:
(559) 441-1214
Facsimile:
(559) 441-1215
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Attorneys for Defendant,
SAFEE AYUB SALAMA
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UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA
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UNITED STATES OF AMERICA,
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Plaintiff,
vs.
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SAFEE AYUB SALAMA,
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Defendant.
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No.: 1:11-CV-00145-OWW-MSJ
STIPULATION TO CONTINUE
SCHEDULING CONFERENCE AND
ORDER
Date:
Time:
Crtm:
Judge:
July 14, 2011
8:15 a.m.
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Oliver W. Wanger,
U.S. District Judge
PLAINTIFF UNITED STATES OF AMERICA through their attorney of record, KIRSTEN
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L. DAEUBLER and DEFENDANT SAFEE AYUB SALAMA through his attorney of record, H. TY
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KHARAZI hereby stipulate to vacate and continue the Scheduling Conference as follows:
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Plaintiff intends to file and has filed a First Amended Complaint to Revoke Naturalization in
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this action. Defendant has consented to permitting Plaintiff to file the amended complaint; a
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stipulation to Amend Complaint has been filed. The First Amended Complaint was filed and
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electronically served on Defendant’s counsel on June 22, 2011.
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Defendant’s counsel has yet to study the First Amended Complaint and therefore, he is not in
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a position to anticipate the issues raised in this amended complaint, formulate a discovery plan and
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anticipate a trial length. Thus, parties believe that a scheduling conference in the above date may be
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premature at this time.
YARRA, KHARAZI
& ASSOCIATES
1250 Fulton Mall
Fresno, CA 93721
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YARRA, KHARAZI
& ASSOCIATES
1250 Fulton Mall
Fresno, CA 93721
STIPULATION TO VACATE AND CONTINUE SCHEDULING CONFERENCE AND ORDER
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Parties, jointly respectfully request that the court continue the current Scheduling Conference
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60 to 90 days. This time will allow Defendant to respond to the Amended Complaint and the parties
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to formulate a discovery plan.
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Plaintiff’s counsel is respectfully requesting that she would be allowed to appear by
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telephone because her office is in Washington DC. Defendant has no objection to the telephonic
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appearance by the plaintiff’s counsel at the scheduling conference.
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Dated: June 23, 2011
/s/ H. Ty Kharazi
___________________________________
H. Ty Kharazi, Attorney for Defendant,
SAFEE AYUB SALAMA
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/s/ Kristen L. Daeubler
___________________________________
Kirsten L. Daeubler, Attorney for Plaintiff,
UNITED STATES OF AMERICA
Dated: June 23, 2011
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ORDER
Based on the forgoing, the Scheduling Conference currently set for July 14, 2011 shall be
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vacated and reset as follows:
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Date: September 30, 2011
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Time: 8:15AM
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Department: 3
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A Joint Scheduling Conference Statement must be electronically filed 7 days before the
hearing date and shall be emailed, in WordPerfect or Word format, to
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owworders@caed.uscourts.gov.
The parties may appear telephonically. Parties are directed to set up a conference call (either
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through the operator or on an internal phone system). After all parties appearing telephonically are
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on one line, call Judge Wanger's chambers at (559) 499-5650 at the time of the hering. Courtroom
YARRA, KHARAZI
& ASSOCIATES
1250 Fulton Mall
Fresno, CA 93721
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YARRA, KHARAZI
& ASSOCIATES
1250 Fulton Mall
Fresno, CA 93721
STIPULATION TO VACATE AND CONTINUE SCHEDULING CONFERENCE AND ORDER
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Deputy Renee Gaumnitz shall be advised by email, rgaumnitz@caed.uscourts.gov, who will be
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appearing telephonically and provided a contact number of the party who is initiating the conference
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call.
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IT IS SO ORDERED.
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Dated:
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June 23, 2011
/s/ Oliver W. Wanger
UNITED STATES DISTRICT JUDGE
DEAC_Signature-END:
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YARRA, KHARAZI
& ASSOCIATES
1250 Fulton Mall
Fresno, CA 93721
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YARRA, KHARAZI
& ASSOCIATES
1250 Fulton Mall
Fresno, CA 93721
STIPULATION TO VACATE AND CONTINUE SCHEDULING CONFERENCE AND ORDER
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