Free Motion for Extension of Time to File Response/Reply - District Court of Delaware - Delaware

Case 1 :07—cv—00264-SLR Document 12 Filed 10/26/2007 Page 1 of 4
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE .
HENRIK OSTERGAARD, : ‘
Plaintiff,
‘ v. Civil Action No. 07—264 (SLR)
MICHAEL CI-IERTOFF, et al.,
n Defendants.
THIRD UNOPPOSED MOTION FOR EXTENSION OF TIME ·
COMES NOW the United States of America, by and- through its attorneys, Colm F.
Connolly, United States-Attorney for the District of Delaware, and Ellen W. Slights, Assistant
United States Attorney fornthe District of Delaware, and respectfully moves this Honorable Court
. for a further extension of time in the above case, until December 28, 2007, for defendants to file
their response to the Complaint. In support thereof] the United States alleges that:
l l. On or about May 16, 2007, plaintiff filed his Complaint for Mandamus Relief and l A A
Petition for Naturalization Pursuant to 8 U.‘s.c. Section l447(B) ("Comp1aint") seeking to
l compel the processing of a naturalization petition filed with the United States Citizenship and f
Iinrnigration Services.
2. The Governn1ent’s response to plaintiff s Complaint was continued to October 29,
2007. - I · _ p
‘ 3. The parties are exchanging information and have made significant progress in
attempting to informally resolve the issues raised in the Complaint. Accordingly, the 1
Govemnient requests more time to accomplish the goal of resolving this matter without further
litigation. I

Case 1:07-cv-00264-SLR Document 12 Filed 10/26/2007 Page 2 of 4 s _
i i 4. Ellen W. Slights, Assistant United States Attomey, contacted counsel for plaintiff who
A said he has no objection to the enlargement of response time and the plaintiff does not oppose the
Government’s motion.
p Vlfherefore, the United States requests that it be allowed until December 28, 2007, to file
its response to the plaintiff s Complaint.
I . COLM F. CONNOLLY
United States Attorney _
i i i By:
- . Ellen W. Slights
Assistant United States Atto y A
_ Delaware Bar I.D. 2782 i
1007 Orange Street, Suite 700 .
Post Office Box 2046 l
. Wilmington, Delaware 19899-2046 .
. (302) 573-6277 .
_ Attorneys for Defendants t
Dated: October 26, 2007 _ A i 1

A Case :07-cv-00264-SLR Document 12 Filed 10/26/2007 Page 3 of 4 i I
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
. HENRIK OSTERGAARD, :
I Plaintiff]
O v. Civil Action No. 07-264 (SLR) H
MICHAEL CHERTOFF, et al.,
I Defendants. ·
_ O R D E R A
I · i I UPON CONSIDERATION ofthe United States’ Third Unopposed Motion for Extension p
of Time, the grounds stated therefor, the plaintiffs’ lack of opposition thereto, and the entire i
record herein, it is this _ day of , 2007, hereby
ORDERED that the United States’ motion should be and it is hereby granted; and it is, I
FURTHER ORDERED that the United States’ response to plaintit`t`s’ Complaint shall be
filed on or before December 28, 2007 . . i
A I 7

Case 1 :07—cv—00264-SLR _ Document 12 Filed 10/26/2007 Page 4 of 4 _
IN THE UNITED STATES DISTRICT COURT
I FOR THE DISTRICT OF DELAWARE
HENRIK OSTERGAARD :
Plaintiff
v. _ Civil Action No. 07-264 (SLR) l
MICHAEL CHERTOF F, et al., A
· Defendants. I
‘ AFFIDAVIT OF SERVICE
` , I, Brandi C. Everett, an employee in the Office ofthe United States Attorney for the
District of Delaware, hereby attest under penalty ofperjury that on October 26, 2007, I
electronically filed the foregoing UNOPPOSED MOTION FOR EXTENSION OF TIME
with the Clerk of Court using ECF, and I hereby attest that I have delivered two copies of said
documents via United States Mail, postage prepaid, to the following:
Lisa Rene Stark . Fabian Lima
Moiris, Nichols, Arsht & Tunnell Law Office of Fabian Lima
1201 North Market Street 1528 Walnut Street _
P.O. Box 1347 . Suite 600
Wilmington, DE 19899 Philadelphia, PA 19102
/s/ Brandi`C. Everett
Brandi C. Everett
Office of the United States Attorney _
The Nemours Building
_ . i 1007 Orange Street
1 Box 2046 t
Wilmington, DE 19899