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

Case 3:01-cv-01782-SRU

Document 14

Filed 02/25/2004

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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)

FEBRUARY 25, 2004

MOTION FOR EXTENSION OF TIME Respondents Immigration and Naturalization Service and Gary Cote, Officer-in-Charge, INS, respectfully move nunc pro tunc for an extension of time of approximately forty-five (45) days, up to and including April 9, 2004, within which to respond to the Court's Order to Show Cause dated October 22, 2003. 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's trial schedule over the

next few weeks is impacting on the ability to file a response within that time frame. This is the second 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

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Filed 02/25/2004

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WHEREFORE, respondents request that the time within which to respond to the Order to Show Cause be extended up to and including April 9, 2004. Respectfully submitted, KEVIN J. O'CONNOR UNITED STATES ATTORNEY /s/ JAMES K. FILAN, JR. ASSISTANT UNITED STATES ATTORNEY Federal Bar No. ct15565 915 Lafayette Blvd. Room 309 Bridgeport, CT 06604 (203) 696-3000

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Case 3:01-cv-01782-SRU

Document 14

Filed 02/25/2004

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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 25th day of February, 2004.

JAMES K. FILAN, JR. ASSISTANT UNITED STATES ATTORNEY

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