Gundogdu v. Blanche et al

STIPULATION TO EXTEND DEADLINES
Case No. 3:26-cv-08294-TSH 	1
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
CRAIG H. MISSAKIAN (CABN 125202)
United States Attorney
KENNETH BRAKEBILL (CABN 196696)
Chief, Civil Division
KELSEY J. HELLAND (CABN 298888)
Assistant United States Attorney
450 Golden Gate Avenue, Box 36055
San Francisco, California 94102-3495
Telephone: (415) 436-7200
FAX: (415) 436-7234
kelsey.helland@usdoj.gov
Attorneys for Defendants
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN FRANCISCO DIVISION
UMUTCAN GUNDOGDU,
Plaintiff,
v.
TODD BLANCHE, in his official capacity as
the Attorney General of the United States, et al.,
Defendants.
)
)
)
)
)
)
)
)
)
)
)
Case No. 3:26-cv-08294-TSH
CORRECTED STIPULATED REQUEST TO
EXTEND TIME FOR DEFENDANTS’
RESPONSE TO PLAINTIFF’S COMPLAINT;
[PROPOSED] ORDER
On October 6, 2026, the court granted the parties’ stipulation to extend time for Defendants’
response, setting Defendants’ response as due on or before November 9, 2026. Dkt. No. 13. The parties
realized a typographical error on the stipulation. The stipulation should reflect that Defendants’ response
is due on or before November 18, 2026, and not November 9, 2026.
Pursuant to Civil Local Rules 6-2 and 7-12, the parties submit the following stipulated request to
extend the time for Defendants’ response to the complaint and the dates in the Court’s Immigration
Mandamus Procedural Order regarding summary judgment. In support of this request, the parties state
as follows:
1. 	Defendants’ response to the complaint is currently due October 19, 2026.
Case 3:26-cv-08294-TSH Document 15 Filed 10/08/26 Page 1 of 2

STIPULATION TO EXTEND DEADLINES
Case No. 3:26-cv-08294-TSH 	2
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
2. 	The parties make this request because the agency is in the process of reviewing this case
and needs a brief period of additional time to prepare their response. Accordingly, they have agreed to
extend the time for Defendants’ response by 30 days.
3. 	The parties therefore stipulate to extend the time for Defendants’ response to November
18, 2026. The parties further request a corresponding extension of the deadlines for filing and briefing a
motion for summary judgment under the Court’s Immigration Mandamus Procedural Order. Dkt. No. 5.
Under the extended deadlines, Defendant’s motion for summary judgment must be filed by January 18,
2027.
4. 	There have been no previous modifications of time in this case, whether by stipulation or
Court order.
IT IS SO STIPULATED.
Dated: October 6, 2026 	Respectfully submitted,
CRAIG H. MISSAKIAN
United States Attorney
/s/ Kelsey J. Helland*
KELSEY J. HELLAND
Assistant United States Attorney
Attorneys for Defendants
Dated: October 6, 2026 /s/ Utku Galip Akcok
UTKU GALIP AKCOK
Akcok Law Office, a Professional Corporation
Attorney for Plaintiff
*The filer of this document hereby attests pursuant to Civil Local Rule 5-1(i)(3) that all signatories have
concurred in the filing of this document.
[PROPOSED] ORDER
Pursuant to stipulation, IT IS SO ORDERED.
Date:
HON. THOMAS S. HIXSON
United States Magistrate Judge
October 8, 2026
Case 3:26-cv-08294-TSH Document 15 Filed 10/08/26 Page 2 of 2