Lopez Polanco v. Lynch et al

Filing 10

ORDER Granting Defendants' 9 Unopposed Motion to Extend Time (First Request) re 1 Complaint. Defendants' answer due 9/30/2015. Signed by Magistrate Judge Cam Ferenbach on 8/31/2015. (Copies have been distributed pursuant to the NEF - SLD)

1 DANIEL G. BOGDEN
United States Attorney
2 KRYSTAL J. ROSSE
Assistant United States Attorney
3 BENJAMIN C. MIZER
Principal Deputy Assistant Attorney General
4 WILLIAM C. PEACHEY
Director
5 ELIZABETH J. STEVENS
Assistant Director
6 TROY D. LIGGETT
Trial Attorney
7 FL Bar No. 0086788
District Court Section
8 Office of Immigration Litigation
Civil Division
9 U.S. Department of Justice
P.O. Box 868, Ben Franklin Station
10 Washington, DC 20044
[phone]; [phone] (fax)
11 [e-mail]
12 Attorneys for Defendants
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UNITED STATES DISTRICT COURT
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DISTRICT OF NEVADA
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ERLING OLMERO LOPEZ POLANCO,
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Plaintiff,
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v.
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LORETTA E. LYNCH, et al.,
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Defendants.
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) Case No. 2:15-cv-01234-JCM-VCF
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DEFENDANTS’ UNOPPOSED MOTION FOR EXTENSION OF TIME

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(First Request)

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Defendants, by and through their attorneys, request a thirty day extension of time to file an

25 appropriate pleading to Plaintiff’s complaint. In support of this motion, Defendants state as follows:
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1.

On June 30, 2015, Plaintiff filed the above-caption Complaint, (ECF No. 1), seeking review

2 under the Administrative Procedure Act of U.S. Citizenship and Immigration Services’ (“USCIS”) denial
3 of Plaintiff’s Petition for U Nonimmigrant Status.
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2.

Defendants have worked diligently to gather information to respond to the Complaint. On

5 August 28, 2015, undersigned counsel received a copy of the 673-page certified administrative record of
6 the adjudication of Plaintiff’s Petition, and has been working with agency counsel to prepare an
7 appropriate response to the Complaint.
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3.

Defendants request the extension because, although they have worked diligently to gather

9 information to respond to Plaintiff’s allegations, Defendants need additional time to provide a complete
10 and thorough response.
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4.

This request is made in good faith and not for purposes of delay, and will not prejudice

12 Plaintiff.
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5.

This is Defendants’ first request for an extension of time to file an appropriate pleading in

14 response to the Complaint.
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6.

On August 28, 2015, undersigned counsel contacted Seth L. Reszko, counsel for Plaintiff,

16 about this motion, and was informed that Plaintiff does not oppose this thirty day extension of time.
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Defendants therefore respectfully request the Court to grant a thirty day extension of time to file an

18 appropriate pleading to respond to Plaintiff’s Complaint, up to and including Wednesday, September 30,
19 2015.
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Respectfully submitted this 31st day of August 2015.

2 DANIEL G. BOGDEN
United States Attorney
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KRYSTAL J. ROSSE
4 Assistant United States Attorney

/s/ Troy D. Liggett
TROY D. LIGGETT
Trial Attorney
FL Bar No. 0086788
District Court Section
Office of Immigration Litigation
Civil Division
U.S. Department of Justice
P.O. Box 868, Ben Franklin Station
Washington, DC 20044
[phone]; [phone] (fax)
[e-mail]

5 BENJAMIN A. MIZER
Principal Deputy Assistant Attorney General
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WILLIAM C. PEACHEY
7 Director
8 ELIZABETH J. STEVENS
Assistant Director
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Attorneys for Defendants

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IT IS SO ORDERED:

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UNITED STATES DISTRICT JUDGE
UNITED STATES MAGISTRATE JUDGE

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DATE:

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August 31, 2015

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PROOF OF SERVICE
I, Troy D. Liggett, certify that the following person was served with a copy of DEFENDANTS’

3 UNOPPOSED MOTION FOR EXTENSION OF TIME on the date, and via the method of service,
4 stated below:
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CM/ECF Notice
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Seth L. Rezko
3365 Pepper Lane
Suite 102
Las Vegas, NV 89120
702-727-7777
[e-mail]
Attorney for Plaintiff

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Dated this 31st day of August 2015.
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/s/ Troy D. Liggett
TROY D. LIGGETT
Trial Attorney
District Court Section
Office of Immigration Litigation
U.S. Department of Justice

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