Muralidharan v. Edlow

Stipulation to Extend
C 5:26-cv-01688 SVK 1
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CRAIG H. MISSAKIAN (CABN 125202)
United States Attorney
KENNETH BRAKEBILL (CABN 196696)
Chief, Civil Division
KELSEY HELLAND (CABN 298888)
Assistant United States Attorney
450 Golden Gate Avenue, Box 36055
San Francisco, California 94102-3495
Telephone: (415) 436-6488
Facsimile: (415) 436-6748
Kelsey.Helland@usdoj.gov
Attorneys for Defendant
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN JOSE DIVISION
SRINATH TUPIL MURALIDHARAN,
Plaintiff,
v.
JOSEPH B. EDLOW, Director, United States
Citizenship and Immigration Services,
Defendant.
Case No. 5:26-cv-01688 SVK
STIPULATION TO EXTEND TIME FOR
DEFENDANT’S RESPONSE TO PLAINTIFF’S
COUNTER-MOTION; AND [PROPOSED]
ORDER
On September 8, 2026, Defendant filed a Motion for Summary Judgment. Dkt. No. 24. On
September 14, 2026, Plaintiff filed a Counter-Motion for Limited Discovery under F.R.C.P. 56(d),
setting Defendant’s response deadline as October 15, 2026. Dkt. No. 25. The parties conferred and
respectfully request the Court to grant an extension for Defendant’s response to Plaintiff’s Counter-
Motion for Limited Discovery, and set Defendant’s response due by October 22, 2026, and Plaintiff’s
reply due by November 5, 2026. The parties make this request because the Assistant United States
Attorney (“AUSA”) handling this matter for Defendant has departed the United States Attorney’s
Office, and the case is being transferred to a new AUSA. The new AUSA needs additional time to
review the matter and prepare a response. The hearing currently scheduled for November 10, 2026, at
11:00 a.m. remains unchanged.
Case 5:26-cv-01688-SVK Document 29 Filed 10/14/26 Page 1 of 3

Stipulation to Extend
C 5:26-cv-01688 SVK 2
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Dated: October 13, 2026 Respectfully submitted,1
CRAIG H. MISSAKIAN
United States Attorney
/s/ Kelsey Helland
KELSEY HELLAND
Assistant United States Attorney
Attorneys for Defendant
Dated: October 13, 2026 /s/ Jessica T. Arena
JESSCIA T. ARENA
Attorney for Plaintiff
[PROPOSED] ORDER
Pursuant to stipulation, IT IS SO ORDERED.
Date: __________________________
SUSAN VAN KEULEN
United States Magistrate Judge
1 In accordance with Civil Local Rule 5-1(i)(3), the filer of this document attests that all
signatories listed herein concur in the filing of this document.
October 14, 2026
Case 5:26-cv-01688-SVK Document 29 Filed 10/14/26 Page 2 of 3

Stipulation to Extend
C 5:26-cv-01688 SVK 3
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Northern District of California and counsel of record for the federal Defendants in the above-captioned
action.
2. On September 8, 2026, Defendant filed a Motion for Summary Judgment. Dkt. No. 24.
On September 14, 2026, Plaintiff filed a Counter-Motion for Limited Discovery under F.R.C.P. 56(d),
setting Defendant’s response deadline as October 15, 2026. Dkt. No. 25.
3. The Assistant United States Attorney (“AUSA”) handling this matter for Defendant has
departed the United States Attorney’s Office, and the case is being transferred to a new AUSA. The new
AUSA will need additional time to review the case and prepare a response.
I declare under penalty of perjury under the laws of the United States of America that the
foregoing is true and correct.
DATED: October 13, 2026
/s/ Kelsey Helland
KELSEY HELLAND
Assistant United States Attorney
DECLARATION OF KELSEY HELLAND
I, Kelsey Helland, declare and state as follows:
1. I am an Assistant United States Attorney in the United States Attorney’s Office for the
Case 5:26-cv-01688-SVK Document 29 Filed 10/14/26 Page 3 of 3