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

Case 1:07-cv-00264-SLR Document 11 Filed 09/13/2007 Page 1 of 4 I
IN THE UNITED STATES DISTRICT COURT I I
- FOR THE DISTRICT OF DELAWARE g
HENRIK OSTERGAARD, :
Plaintiff, ‘ l . '
if _ v. n ‘ Civil Action No. 07-264 (SLR) · S
. MICHAEL CHERTOFF, etal., - I -
` · . Defendants. I I
I I I SECOND UNOPPOSED MOTION FOR EXTENSION OF TIME
I y .0 COMES NOW the United States of America, by and through its attorneys, Colm F. Z
‘ Connolly, United States Attorney for the District of Delaware, and Ellen W. Slights, Assistant
I _ I United States Attorney for the District of Delaware, and respectfully moves this Honorable Court I
I for a further extension of time in the above case, until October 29, 2007, for defendants to file n I
their response to the Complaint. In support thereof, the United States alleges that: l
l l l l. On or about May 16, 2007, plaintiff filed his Complaint for Mandamus Relief and i
Petition for Naturalization Pursuant to 8 U.S.C. Section l447(B) (“Complaint") seelring to
compel the processing of a naturalization petition filed with the United States Citizenship and 2
Immigration Services. I I I
I 2. The Government’s response to plaintiffs Complaint was continued to September 13, Q
g 2007. · n I
. · 3. The parties are attempting to informally resolve the issues raised in the Complaint and I i
» ` need more time to accomplish their goals.

Case 1 :O7—cv—OO264-SLR Document 11 Filed O9/13/2007 Page 2 of 4 -
a 4. Ellen W. Slights, Assistant United States Attorney, contacted counsel for plaintiff who
said he has no objection to the enlargement of response time and the plaintiff does not oppose the
A Gove1in.ment’s motion. ·
. Vlfherefore, the United States requests- that it be allowed until October 29, 2007, to file its
response to the plaintiffs Complaint. · ·
‘ - COLM F. CONNOLLY . I _
United States Attorney
By: ‘ ·
Ellen W. Slights ‘
_ - Assistant United States Attorney e
Delaware Bar I.D. 2782 I ¥
` 1007 Orange Street, Suite 700 . .
Post Office Box 2046 _ I
. I Wilmington, Delaware 19899-2046
. (302) 573-6277
Attorneys for Defendants
g Dated: September 13, 2007 ·

Case 1 :O7—cv—OO264-SLR Document 11 Filed O9/13/2007 Page 3 of 4 ‘
i IN THE UNITED STATES DISTRICT COURT __
FOR THE DISTRICT OF DELAWARE . _
HENRIK OSTERGAARD, _ 2
Plaintifi .
_ _ v. _ i Civil Action No. 07-264 (SLR) i i —
i MICHAEL CHERTOFF, etal., I I
Defendants. _ ` _
e O R D E R _`
p - UPON CONSIDERATION of the United States’ Second Unopposed Motion for ` ‘
Extension of Time, the grounds stated therefor, the plaintiffs’ lack of opposition thereto, and the
- entire record herein, it is this _____- day of , 2007, hereby i
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 plaintiffs’ Complaint shall be
filed on or before October 29, 2007 . i I ‘
U A 2 U H U

Case.1:07—cv-00264-SLR Document 11 _ Filed O9/13/2007 Page 4 of 4
· IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE p
HENRIK OSTERGAARD ‘ :
Piaimirg 7 { A
I _v. . Civil Action No-. 07-264 (SLR) I I
MICHAEL- CHERT OFF, et- a1_., . n
· _ Defendants. C M n
. A 'AFFIDAVIT OF SERVICE -
C I, Brandi C. Everett, an employee in the Office ofthe United States Attorney for the
" District of Delaware, hereby attest under penalty of perjury that on September 13, 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 _ _ n Fabian Lima U
i Morris, Nicho1s,.Arsht & Tu11nell Law Office of Fabian Lima _
1201 North Market Street P 1528 Walnut Street ` 1
P.O. Box 1347 p Suite 600 ` ‘ {
_ n Wilmington, DE 19899 t Philadelphia, PA 19102 _ - 1
U U V /s/ Brandi C. Everett
l A _ Brandi C. Everett l
I Office of the United States Attorney ` ‘
The Nemours Building
. _ . 1007 Orange Street
P.O. Box 2046 A ‘
` _ Wihnington, DE 19899 .