Thodima v. Mullin et al

STIPULATION TO EXTEND
Case No. 5:26-cv-07738 SVK 1
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CRAIG H. MISSAKIAN (CABN 125202)
United States Attorney
KENNETH BRAKEBILL (CABN 196696)
Chief, Civil Division
JOHN L. WOLLMAN (CABN 197362)
Assistant United States Attorney
450 Golden Gate Avenue, Box 36055
San Francisco, California 94102-3495
Telephone: (415) 436-7031
Facsimile: (415) 436-7234
John.Wollman@usdoj.gov
Attorneys for Defendants
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN JOSE DIVISION
SHUSHMA THODIMA,
Plaintiff,
v.
MARKWAYNE MULLIN, Secretary, United
States Department of Homeland Security, et al.,
Defendants.
Case No. 5:26-cv-07738 SVK
STIPULATION TO EXTEND TIME FOR
DEFENDANTS’ RESPONSE TO PLAINTIFF’S
COMPLAINT; AND [PROPOSED] ORDER
The parties, through their undersigned attorneys, hereby stipulate to an extension of time for
Defendants’ response to Plaintiff’s complaint. Defendants will file their response on or before
November 9, 2026. 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.
The parties further request a corresponding extension to the deadline for filing a summary
judgment motion under the Court’s Immigration Mandamus Procedural Order. Dkt. No. 4. Currently,
Defendants must file a motion for summary judgment by 120 days after the complaint was served, or
December 11, 2026. In view of the agreed-upon extension for Defendants’ response to the complaint,
the parties request that Defendants must file their motion for summary judgment by January 11, 2027.
Case 5:26-cv-07738-SVK Document 11 Filed 10/14/26 Page 1 of 3

STIPULATION TO EXTEND
Case No. 5:26-cv-07738 SVK 2
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Dated: October 8, 2026 Respectfully submitted,1
CRAIG H. MISSAKIAN
United States Attorney
/s/ John L. Wollman
JOHN L. WOLLMAN
Assistant United States Attorney
Attorneys for Defendants
Dated: October 8, 2026 /s/ Arash Yasrebi
ARASH YASREBI
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-07738-SVK Document 11 Filed 10/14/26 Page 2 of 3

STIPULATION TO EXTEND
Case No. 5:26-cv-07738 SVK 3
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DECLARATION OF JOHN L. WOLLMAN
I, John L. Wollman, declare and state as follows:
1. I am an Assistant United States Attorney in the United States Attorney’s Office for the
Northern District of California and counsel of record for the federal Defendants in the above-captioned
action.
2. On July 26, 2026, Plaintiff filed a complaint in which she seeks adjudication of her Form
I-485, Application to Register Permanent Residence or Adjust Status. See Dkt. No. 1. The case was
served on our office on August 13, 2026.
3. My office has been conferring with the agency regarding this case, and we determined
that Defendants need a brief period of additional time to prepare their response. Accordingly, my office
contacted Plaintiff’s counsel regarding Defendants’ request for an extension of time and Plaintiff
consented to the request.
I declare under penalty of perjury under the laws of the United States of America that the
foregoing is true and correct.
DATED: October 8, 2026
/s/ John L. Wollman
JOHN L. WOLLMAN
Assistant United States Attorney
Case 5:26-cv-07738-SVK Document 11 Filed 10/14/26 Page 3 of 3