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

I Case 1 :06-cv—O0777-JJF Document 7 Filed O4/O9/2007 Page 1 of 4
IN THE UNITED STATES DISTRICT COURT I
FOR THE DISTRICT OF DELAWARE ‘ .
I ARSALAN FAGHRI, :
FERESHTEH AMINI and _ : ` _
. ROUDABEH F AGHRI, :
_ Plaintiffs, _ I _
. e v. I Civil Action No. 06-777-*** ‘
SECRETARY MICHAEL CHERTOFF, et al.,
‘ Defendants. I _ -
UNOPPOSED MOTION FOR EXTENSION OF TIME I
g I COMES NOW the United S_tates of America, by and through its attorneys, Colm F. .
I Connolly, United States Attorney for the District of Delaware, and Ellen W. Slights, Assistant .
United States Attorney for the District of Delaware, and respectfully moves this Honorable Court _
for an extension of time in the above case, until Friday, April 13, 2007, for defendants to file
I their response to the Complaint. In support thereof the United States alleges that: -
1. On or about December 20, 2006, plaintiffs filed their Original Complaint for Writ of _
` Mandamus (“Complaint") seeking to compel the processing of an adjustment of status request _
filed with the United States Citizenship and Immigration Services. p
. 2. The Government’s response to plaintiffs’ Complaint is due on April 9, 2007.
3. The undersigned counsel has only very recently received the information necessary to
prepare a responseto the plaintiffs’ Complaint. Counsel requests this four day extension to
obtain further information and to allow the govemment time to formulate an adequate response. U
_ 4. The undersigned counsel contacted p1aintiffs’ counsel, Ms. Badmus, regarding this
_ motion seeking enlargement of time in which to respond to the Complaint. Ms. Badmus I ;

Case 1:06-cv—OO777-JJF Document 7 Filed O4/O9/2007_ Page 2 of 4
indicated plaintiffs have no objection to such an enlargement of time and the plaintiffs do not
oppose the Government’s motion.
Wherefore, the United States requests that it be allowed until Friday, April 13, 2007, to
tile its response to the plaintiffs’ Complaint. _ -
COLM F. CONNOLLY I
Unit d States Attomey p
‘ a A A a Bw
Ellen W. Slights
" Assistant United States Attorney
. Delaware Bar LD. 2782
1007 Orange Street, Suite 700
Post Office Box 2046
Wilmington, Delaware 19899-2046
(302) 573—6277 F _
_ A Attonieys for Defendants -
l Dated: April 9, 2007 " . i

Case 1 :06-cv—O0777>JJF Document 7 Filed O4/O9/2007 Page 3 of 4
` IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
ARSALAN FAGHRI, : l l-
FERESHTEH AMINI and - :
ROUDABEH FAGHRI, : .
_ l Plaintiffs, i
i i v. _ Civil Action No. 06-777-*** I I
p SECRETARY MICHAEL CHERTOFF, et al.,
- . Defendants. ·
onnnn A -
· UPON CONSIDERATION of the United States’ Unopposed Motion for Extension of ·
Time, the grounds stated therefor, the plaintiffs’ lack of opposition thereto, and the entire record
. herein, it is this M; day of , 2007, hereby .
ORDERED that the United States’ motion should be and it is hereby granted; and it is, -
A. FURTHER ORDERED that the United States’ Answer to p1aintiffs’ Complaint shall be
. filed on or before Friday, April 13, 2007. I A

Case 1 :06-cv—O0777-JJF Document 7 Filed O4/O9/2007 Page 4 of 4
. IN THE UNITED STATES DISTRICT COURT
_ FOR THE DISTRICT OF DELAWARE
ARSALAN FAGHRI, : q
FERESHTEH AMINI and :
ROUDABEH FAGHRI, :
n Plaintiffs,
v. Civil Action No. 06-777-*** .
I SECRETARY MICHAEL CHERTOFF, et al.,
n » an Defendants. _ A
r ‘ AFFIDAVIT OF SERVICE _
7 I, Kathie Gray, an employee in the Office of the United States Attomey for the District of
Delaware, hereby attest under penalty of peijuiy that on April 9, 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: - _
Cynthia L. Carroll, Esquire
260 Chapman Road ‘
Suite 201-D ‘
Newark, DE 19702
Ann Massey Badmus, Esquire ` U
l Badmus Immigration Law Firm P.C.
l 12700 Park Central Drive
Suite 1910
Dallas, TX 75251
- /9/ Kathie Gray
Kathie Gray U l
Office of the United States Attorney _ -
- The Nemours Building ‘ _
p 1007 Orange Street
_ P.O. Box 2046 -
q Wilmington, DE 19899 ·