Free Motion for Extension of Time - District Court of Delaware - Delaware

° Case 1 :O6—cv—OO777-JJF Document 12 Filed O4/26/2007 Page 1 of 4
I IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
ARSALAN FAGHRI, :
FERESHTEH AMIM , :
and ROUDABEH FAGHRI, :
Plaintiffs,
· v. : Civil Action No. 06-777-* **
I SECRETARY MICHAEL CHERTOFF, et al., :- I
Defendants.
UNOPPOSED MOTION FOR EXTENSION OF TIME
COMES NOW the plaintiffs, Arsalan Faghri, et. al, by and through their attorneys, Ami
Massey Badmus and Cynthia L. Carroll, and respectfully moves this Honorable Court for an
extension of time in the above case, until Friday, May 11, 2007, for plaintiffs to tile their
response to the defendants’ Motion to Dismiss. In support thereof, the plaintiffs allege that:
1. On or about April 13, 2007, defendants filed their Motion to Dismiss pursuant to
Federal Rule of Civil Procedure 12(b)(l) ("Motion”) seeking to dismiss plaintiffs’ Complaint.
Plaintiffs received service of the Motion on April 16, 2007.
2. The plaintiffs’ response to the Motion is due on April 27, 2007.
3. The undersigned counsel contacted the defendants’ counsel, Ellen Sleights, regarding
this motion seeking enlargement of time in which to respond to the Motion. Ms. Sleights
indicated that defendants have no objection to enlargement of time and the defendants’ do no
opposed the plaintiffs’ motion.
Wherefore, the plaintiffs request that they be allowed until Friday, May ll, 2007, to tile
its response to the defendants’ Motion to Dismiss.
:1
; V-"gjg*ié

~ Case 1 :O6—cv—OO777-JJF Document 12 Filed O4/26/2007 Page 2 of 4
Ami Massey Badmus
Attorney at Law
Badmus Immigration Law Firm, P.C.
Bar 1.D. 2717
12700 Park Central Drive Suite 1910
Dallas, Texas 75251
469-916-7900
Dated: April 25, 2007

~ Case 1 :O6—cv—OO777-JJF Document 12 Filed O4/26/2007 Page 3 of 4
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
ARSALAN FAGHRI, :
FERESHTEH AMIM , :
and ROUDABEH FAGHRI, :
Plaintiffs,
v. : Civil Action No. 06-777-***
I I SECRETARY MICHAEL CHERTOFP, et al., zl I I
Defendants. »
ORDER
UPON CONSIDERATION of the plaintiffs’ Motion for Extension of Time, the grounds
V stated therefore, and the entire record herein, it is this _ day of _, 2007, hereby
ORDERED that the plaintiffs’ motion should and it is hereby granted; and it is,
FURTHER ORDERED that the plaintiffs’ brief in response to the defendants’ Motion to
Dismiss shall be filed on or before May ll, 2007.

I K. Case 1:O6—cv—OO777-JJF Document 12 Filed O4/26/2007 Page 4 of 4
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
ARSALAN FAGHRI, :
FERESHTEH AMIM , :
and ROUDABEH FAGHRI, :
Piaimirrs, Q
v. : Civil Action No. 06-777-* * *
I SECRETARY MICHAEL CHERTOFF, et al., zu
Defendants.
CERTIFICATE Q SERVICE
I hereby certify that a copy of the foregoing MOTION FOR EXTENSION OF TIME was served
by certified mail, postage prepaid and hand delivery as follows:
The Honorable Colm F. Connolly
United States Attorney's Office
District of Delaware I
P.O. Box 2046
Wilmington, Delaware 1989@M
Ann Massey Badmus
Attorney at Law
Badmus Immigration Law Firm, P.C.
Bar I.D. 2717
12700 Park Central Drive Suite 1910
Dallas, Texas 75251
469-916-7900