Free Motion for Extension of Time to File Answer - District Court of Delaware - Delaware

Case 1:07-cv-00264-SLR Document 10 Filed 08/13/2007 Page 1 of 4
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
HENRIK OSTERGAARD, :
Plaintifi I
v. Civil Action No. 07-264 (SLR)
MICHAEL CHERTOFF, et al.,
Defendants. p
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
I United States Attomey for the District of Delaware, and respectfully moves this Honorable Court A
for an extension of time in the above case, until September 13, 2007, for defendants to tile their
response to the Complaint. In support thereof; the United States alleges that:
an 1. On or about May 16, 2007, plaintiff filed his Complaint for Mandamus Relief and
Petition for Naturalization Pursuant to 8 U.S.C. Section 1447(B) ("Cornplaint") seeking to
compel the processing of a naturalization petition tiled with the United States Citizenship and
Immigration Services. l
2. The Government’s response to plaintiffs Complaint is due on August I4, 2006.
if I 3. The parties are attempting to infonnally resolve the issues raised in the Complaint.
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
Government’s motion. l l

Case 1:07-cv-00264-SLR Document 10 Filed 08/13/2007 Page 2 of 4
Wherefore, the United States requests that it be allowed until September 13, 2007, to file
its response to the plaintiffs Complaint.
COLM F. CONNOLLY
United States Attorney
. By:
Ellen W. Slthts
Assistant United States Attorney ~
` Delaware Bar I.D. 2782
1007 Orange Street, Suite 700
I · . Post Office Box 2046 _ _ .
Wilmington, Delaware 19899-2046 ‘
_ . - (302) 573-6277
_ Attorneys for Defendants
Dated: August 13, 2007

Case 1:07-cv-00264-SLR Document 10 Filed 08/13/2007 Page 3 of 4 I
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
HENRIK OSTERGAARD, :
Plaintifi
v. Civil Action No. 07-264 (SLR)
MICHAEL CHERTOFF, et al.,
Defendants.
O R D E R
UPON CONSIDERATION of the United States’ Unopposed Motion for Extension of
Time, the grounds stated therefor, the p1aintift`s’ lack of opposition thereto, and the entire 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,
FURTHER ORDERED that the United States’ Answer to plaintiffs’ Complaint shall be
filed on or before September 13, 2007 . ' `
a

Case 1:07-cv-00264-SLR Document 10 Filed 08/13/2007 Page 4 of 4
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
HENRIK OSTERGAARD :
Plaintiff,
I v. Civil Action N0. 07-264 (SLR)
l\/[ICHAEL CHERTOFF, et al.,
Defendants.
AFFIDAVIT OF SERVICE
I, Brandi C. Everett, an employee in the Office of the United States Attorney for the
District of Delaware, hereby attest under penalty of perjury that on August 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 Fabian Lima
Morris, 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 ofthe United States Attorney ·
- . . ‘ . · The Nemours Building
_ . . _ 1007 Orange Street
· . P.O. Box 2046
Wilmington, DE 19899 `