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

Case 3:01-cv-01782-SRU

Document 12

Filed 11/24/2003

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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)

NOVEMBER 24, 2003

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 forty-five (45) days, up to and including January 8, 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 consulting with staff at the Department of Justice's Office of Immigration Litigation in formulating a response to the amended petition and additional time is needed to finalize that response. This is the first 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 12

Filed 11/24/2003

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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 January 8, 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 12

Filed 11/24/2003

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 24th day of November, 2003.

JAMES K. FILAN, JR. ASSISTANT UNITED STATES ATTORNEY

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