STIPULATION AND [PROPOSED] ORDER RE OSC BRIEFING SCHEDULE

NATHANAEL COUSINS, District Judge.

Whereas, on November 30, 2014, petitioner filed a petition for writ of habeas corpus.

Whereas, on December 5, 2014, petitioner filed a motion for stay of removal.

Whereas, on December 15, 2014, Magistrate Judge Cousins issued an order granting application for order to show cause; order to respondents to show cause why petition for writ of habeas corpus should not be granted; and order setting briefing schedule on motion for stay of removal. Pursuant to that order, respondents' response is due December 18, 2014, and petitioner's reply is due December 19, 2014. In that order, the Court stated: "The briefing and hearing schedule may be modified by further court order. The Court encourages the parties to confer with each other and to propose an amended schedule if they will be unable to comply with the schedule set by this order."

Whereas, on December 15, 2014, the United States Attorney's Office first received the aforesaid petition, motion, and order, and assigned the case to AUSA James A. Scharf.

Whereas, on December 16, 2014, AUSA Scharf first spoke to agency counsel Michael Steinberg about this case.

Whereas, on December 16, 2014, AUSA Scharf and Lamar Peckham, attorney for petitioner, met and conferred about the briefing schedule as per the Court's suggestion.

Whereas, respondent agrees to not remove petitioner until the petition for writ of habeas corpus is resolved.

Whereas, the parties are actively exploring a possible settlement of this case.

Whereas, AUSA Scharf requires additional time to research potential legal and factual defenses to the petition and motion, and to draft a response, in the event the parties are unable to settle this matter.

Whereas, AUSA Scharf will out of the office and unavailable to work on this case between December 25, 2014, and January 4, 2015, due to the holidays.

Therefore, the parties request that the Court extend the date by which respondents shall file a response to January 9, 2015, and the date by which petitioner shall file a reply to January 16, 2015, with the Court to set a hearing date after the briefing has been completed on a date and time convenient to the Court.

[PROPOSED] ORDER

Pursuant to the stipulation of the parties, and based on good cause, it is hereby ordered that respondent's response is due January 9, 2015, and petitioner's reply is due January 16, 2015. The Court will hear the matter on ____________________________________________________________________________________ ___________________________________________________________________________________.