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

Case 3:01-cv-01782-SRU

Document 16

Filed 04/12/2004

Page 1 of 3

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT MARIE FIDELINA-PEREZ, Petitioner, v. IMMIGRATION & NATURALIZATION SERVICE and GARY COTE, Officer-in-Charge, INS, Respondents. : : : : : : : : : CIV. NO. 3:01CV01782 (SRU)

APRIL 12, 2004

MOTION FOR EXTENSION OF TIME Respondents Immigration and Naturalization Service and Gary Cote, Officer-in-Charge, INS, respectfully move for an extension of time of approximately thirty (30) days, up to and including May 12, 2004, within which to respond to the Court's Order to Show Cause. The reason for this request is that the undersigned is still consulting with staff at the Department of Justice's Office of Immigration Litigation in formulating a response to the amended petition. Moreover, the undersigned had to address an

unanticipated family medical emergency that impacted his ability to file a response within the previous time frame. This is the third request for extension of time with regard to this deadline. Counsel for petitioner does not object to the

granting of this request.

Case 3:01-cv-01782-SRU

Document 16

Filed 04/12/2004

Page 2 of 3

WHEREFORE, respondents request that the time within which to respond to the Order to Show Cause be extended up to and including May 12, 2004. Respectfully submitted, KEVIN J. O'CONNOR UNITED STATES ATTORNEY

JAMES K. FILAN, JR. ASSISTANT UNITED STATES ATTORNEY Federal Bar No. ct15565 915 Lafayette Blvd. Room 309 Bridgeport, CT 06604 (203) 696-3000

2

Case 3:01-cv-01782-SRU

Document 16

Filed 04/12/2004

Page 3 of 3

CERTIFICATION This is to certify that a copy of the foregoing was sent United States Mail, postage prepaid, on this date, to: James E. Swaine 234 Church Street, Suite 300 New Haven, CT 06510 Inmate Dated at Bridgeport, Connecticut this 12th day of April, 2004.

JAMES K. FILAN, JR. ASSISTANT UNITED STATES ATTORNEY

3