Defendants’ Second Unopposed Motion for an Extension of Time to Answer or Otherwise Respond – Page 1

IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF TEXAS

DALLAS DIVISION

_____________________________________

MICHEL SOUZA MEDEIROS, et al., 

Plaintiffs,

v.

UNITED STATES CITIZENSHIP AND 

IMMIGRATION SERVICES, et al.,

Defendants.

Civil Action No. 3:22-cv-00723-G 

DEFENDANTS’ SECOND UNOPPOSED MOTION FOR AN

EXTENSION OF TIME TO ANSWER OR OTHERWISE RESPOND

In this case, Plaintiffs seek a writ of mandamus to compel U.S. Citizenship and 

Immigration Services (USCIS) to adjudicate a Form I-140, “Immigrant Petition for Alien 

Workers,” and Forms I-485, “Application to Register Permanent Residence or Adjust 

Status.” See Doc. 1 at 2, 6–7. On May 26, 2022, the Court granted Defendants’ 

unopposed motion for a 75-day extension of time to answer or otherwise respond to the 

complaint, due to a request for evidence that USCIS issued to Plaintiff Michel Souza 

Medeiros in connection with the Form I-140. See Docs. 10, 11. Pursuant to Federal Rule 

of Civil Procedure 6(b)(1)(A), Defendants respectfully move the Court for an additional 

extension of time to answer or otherwise respond to the complaint—an additional 60 

days—which would extend the response deadline from August 17, 2022 to October 17, 

2022. The reason for this additional extension request is that Plaintiff has not yet 

responded to the request for evidence. Plaintiffs’ counsel informed Defendants’ counsel 

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Defendants’ Second Unopposed Motion for an Extension of Time to Answer or Otherwise Respond – Page 2

that Plaintiff expects to submit the response within the next couple of weeks. Upon 

receipt of a response to the request, USCIS will resume processing the applications at 

issue. USCIS expects that, by October 17, 2022, it will have either completed 

adjudicating the applications, rendering the lawsuit moot, or at least be in a significantly 

better position to determine what additional steps may be necessary before completing 

adjudication. Plaintiffs do not oppose this extension request. Therefore, Defendants 

respectfully move the Court for a 60-day extension of time to answer or otherwise 

respond to Plaintiffs’ complaint, from August 17, 2022 to October 17, 2022. 

Respectfully submitted,

CHAD E. MEACHAM

UNITED STATES ATTORNEY

/s/ Lisa R. Hasday

Lisa R. Hasday

Assistant United States Attorney

Texas Bar No. 24075989

1100 Commerce Street, Third Floor

Dallas, Texas 75242-1699

Telephone: 214-659-8737

Facsimile: 214-659-8807

lisa.hasday@usdoj.gov

Attorneys for Defendants

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Defendants’ Second Unopposed Motion for an Extension of Time to Answer or Otherwise Respond – Page 3

Certificate of Conference

I certify that, on August 3, 2022, I conferred with Plaintiffs’ counsel regarding this 

motion, and counsel stated that Plaintiffs do not oppose the motion.

 /s/ Lisa R. Hasday

Lisa R. Hasday

Assistant United States Attorney

 

Certificate of Service

On August 3, 2022, I electronically submitted the foregoing document with the 

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

case filing system of the court. I hereby certify that I have served all parties 

electronically or by another manner authorized by Federal Rule of Civil Procedure 

5(b)(2).

/s/ Lisa R. Hasday

Lisa R. Hasday

Assistant United States Attorney

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