Avramski v. United States et al

Filing 11

ORDER Granting 8 Defendant's Unopposed Motion to Extend Time to Answer 1 Complaint. United States answer due 4/10/2013. Signed by Magistrate Judge Carl W. Hoffman on 03/12/2013. (Copies have been distributed pursuant to the NEF - AC)

Case 2:12-cv-02167-GMN-CWH Document 8 Filed 03/11/13 Page 1 of 3

1

6

DANIEL G. BOGDEN
United States Attorney
District of Nevada
Nevada Bar No. 2137
CARLOS A. GONZALEZ
Assistant United States Attorney
333 Las Vegas Blvd. So., #5000
Las Vegas, Nevada
89101
Ph: [phone]
Fax: [phone]
E-mail: [e-mail]

7

Attorneys for the United States.

2
3
4
5

8

UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

9
10

BORIS ANGUELOV AVRAMSKI,

11

Plaintiff,

12

v.

13

UNITED STATES, et al.,

14

Respondents.

)
)
)
)
)
)
)
)
)
)

Case No. 2:12-cv-02167
UNOPPOSED MOTION FOR 30 DAY
EXTENSION OF TIME TO ANSWER,
PLEAD, OR OTHERWISE RESPOND
TO PLAINTIFF’S COMPLAINT FOR
WRIT OF MANDAMUS AND
DECLARATORY RELIEF

15
16

The United States of America by and through Daniel G.

17

Bogden, United States Attorney for the District of Nevada, and

18

Carlos A. Gonzalez, Assistant United States Attorney, without

19

waiving any defenses that may be available in this case, for the

20

reasons set forth below, the Defendants move this Court for an

21

unopposed 30-day extension of time, from March 11, 2013, to and

22

including April 10, 2013, by which to answer, plead, or otherwise

23

respond to Boris Anguelov Avramski’s (“Plaintiff”) Petition for

24

Writ of Mandamus and Declaratory Relief (“Complaint”).

25

...

26

...

Case 2:12-cv-02167-GMN-CWH Document 8 Filed 03/11/13 Page 2 of 3

Plaintiff has petitioned the Court, inter alia, for a writ

1
2

of mandamus compelling the Defendants to grant his naturalization

3

application.

4

answer, plead, or otherwise respond to Plaintiff’s Complaint by

5

March 11, 2013.

6

respond, Defendants have been coordinating with agency counsel,

7

gathering documents, and determining their defenses.

8

Simultaneously, the parties to this action are exploring avenues

9

to resolve this litigation.

10

Defendants have been diligently preparing to

In preparation to answer, plead, or otherwise

As the parties seek to resolve the dispute giving rise to

11

this litigation, counsel for Defendants requests an additional 30

12

days to answer, plead, or otherwise respond to Plaintiff’s

13

Complaint.

14

matter, Defendants expect to be in position to answer, plead, or

15

otherwise respond to the Plaintiff’s Complaint by April 10, 2013.

16

Should the parties not be able to resolve this

Counsel for the Defendants has conferred with counsel for

17

Plaintiff, Peter L. Ashman, who has no opposition to this request

18

for an extension of time.

19

...

20

...

21

...

22

...

23

...

24

...

25

...

26

...
-2-

Case 2:12-cv-02167-GMN-CWH Document 8 Filed 03/11/13 Page 3 of 3

--

1
2

Accordingly, Defendants request an extension of time, from

3

March 11, 2013, to and including April 10, 2013, by which to

4

answer, plead, or otherwise respond to Plaintiff’s Complaint.

5
Dated:

March 11, 2013

Respectfully submitted,

6
7

DANIEL G. BOGDEN
United States Attorney

8

//s// Carlos A. Gonzalez
Assistant United States Attorney

9
10
11

OF COUNSEL:

12

STUART F. DELERY
Principal Deputy Assistant Attorney General
Civil Division
DAVID J. KLINE
Office of Immigration Litigation
Director, District Court Section
SAMUEL P. GO
Office of Immigration Litigation
Senior Litigation Counsel, District Court Section
JOHN J. W. INKELES
Office of Immigration Litigation
U.S. Department of Justice, Civil Division
Trial Attorney, District Court Section
P.O. Box 868, Ben Franklin Station
Washington, DC 20044
Tel: [phone]
Fax: [phone]
[e-mail]
Counsel for Defendants

13
14
15
16
17
18
19
20
21
22
23

IT IS SO ORDERED.
DATED: March 12, 2013.

24
25

_________________________________
UNITED STATES MAGISTRATE JUDGE

26
-3-