MOTION TO EXTEND TIME Page 1 

IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF TEXAS

DALLAS DIVISION

The STATE OF TEXAS, et. al., § 

 § 

Plaintiffs, § 

§ CIVIL ACTION NO. 3:22–cv–00780-m 

 vs. § 

§ 

JOSEPH R. BIDEN, JR., § 

in his official capacity as § 

President of the United States, et al., § 

 § 

Defendants, § 

§ 

and § 

§ 

TIMOTEO et al., § 

§ 

Intervenor-Defendants. § 

UNOPPOSED MOTION TO EXTEND TIME

On September 6, 2023, the Court granted the unopposed Motion to Intervene of 

Defendant-Intervenors Antonio, Magdalena, Marta, and Elizabeth (“2023 DefendantIntervenors”). ECF No. 115, Order. In its order, the Court instructed 2023 Defendant-Intervenors 

to file a responsive pleading or a motion pursuant to Federal Rule of Civil Procedure 12(b) by 

September 13, 2023. Id. Separately, on August 21, 2023, the Court ordered a schedule for further 

proceedings for the existing Plaintiffs, Defendants, and Defendant-Intervenors. ECF No. 107. 

With all parties’ consent, the 2023 Defendant-Intervenors respectfully request an 

extension of time to file a responsive pleading or a motion pursuant to Fed. R. Civ. P. 12(b) such 

that they will follow the same schedule for further proceedings as the Court ordered for all other 

parties in its August 21, 2023 Order. See id. As such, pursuant to the schedule ordered in ECF 

No. 107, the 2023 Defendants-Intervenors would be subject to the following relevant deadlines: 

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MOTION TO EXTEND TIME Page 2 

Event Deadline

2023 Defendant-Intervenors to file any motion 

to dismiss

October 16, 2023

2023 Defendant-Intervenors to file any reply in 

support of any motion to dismiss

November 20, 2023

Parties to meet and confer and to file a joint 

status report proposing a schedule for the 

remainder of the case

30 days after any order on any motions to 

dismiss. 

The 2023 Defendant-Intervenors thank the Court for its consideration of this request. 

Dated: September 7, 2023 Respectfully submitted,

/s/ Debra J. McComas /s/ Kathryn C. Meyer

Debra J. McComas Kathryn C. Meyer 

NYS Bar #5504485 (pro hac vice)

HAYNES & BOONE LLP Linda B. Evarts 

NYS Bar #5236948 (pro hac vice)

State Bar No. 00794261 Mariko Hirose 

NYS Bar #4802674 (pro hac vice)

2323 Victory Ave., Suite 700 INTERNATIONAL REFUGEE 

Dallas, Texas 75219 ASSISTANCE PROJECT

Tel. (214) 651-5000 One Battery Park Plaza, 4th Floor

Fax (214) 651-5940 New York, NY 10004

debbie.mccomas@haynesboone.com Tel. (516) 838-1655

Fax: (929) 999-8115

kmeyer@refugeerights.org 

levarts@refugeerights.org

mhirose@refugeerights.org

Counsel for Defendant-Intervenors

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MOTION TO EXTEND TIME Page 3 

CERTIFICATE OF CONFERENCE

On September 7, 2023, counsel for Defendant-Intervenors conferred with counsel for 

Plaintiffs and Defendants concerning this motion. The identities of the attorneys conferring were 

as follows: Ryan Walters for the Plaintiffs, Joseph Darrow for the Defendants, and Kathryn C. 

Meyer for the Defendant-Intervenors. Plaintiffs, Defendants, and Defendant-Intervenors do not 

oppose 2023 Defendant-Intervenors’ motion to extend time. 

CERTIFICATE OF SERVICE

 The undersigned certifies that on September 7, 2023, I electronically filed the foregoing 

document with the Clerk of Court for the U.S. District Court, Northern District of Texas, using 

the CM/ECF system. I hereby certify that I have served the documentation on all counsel by a 

manner authorized by Federal Rule of Civil Procedure 5(b)(2) via the Court’s CM/ECF filing 

system. 

/s/ Kathryn C. Meyer

Kathryn C. Meyer 

Case 3:22-cv-00780-M Document 117 Filed 09/07/23 Page 3 of 3 PageID 1774