Defendants’ 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’ 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. Pursuant to Federal Rule of Civil Procedure 6(b)(1)(A),

Defendants respectfully move the Court for a 75-day extension of time to answer or 

otherwise respond to the complaint, which would extend the response deadline from June 

3, 2022 to August 17, 2022. The reason for this extension request is that, on April 20, 

2022, USCIS issued a request for evidence to Plaintiff Michel Souza Medeiros in 

connection with the Form I-140. A response to the request for evidence is due by July 

18, 2022, which constitutes the maximum period allowed for responding to requests for 

evidence. See 8 C.F.R. § 103.2(b)(8)(iv) (“The request for evidence . . . will indicate the 

deadline for response, but in no case shall the maximum response period provided in a 

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

request for evidence exceed twelve weeks . . . .”).1 Upon receipt of a response to the 

request for evidence, USCIS will resume processing the applications at issue. USCIS 

expects that, by August 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 75-day extension of time to answer or otherwise respond to Plaintiffs’

complaint, from June 3, 2022 to August 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

1 Defendants note that, in response to the Covid-19 pandemic, USCIS has extended flexibilities for responding to 

agency requests and, before taking any action, the agency will consider a response to a request for evidence that is 

received within 60 calendar days after the response due date set in the request. See

https://www.uscis.gov/newsroom/alerts/uscis-extends-flexibility-for-responding-to-agency-requests-1.

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

Certificate of Conference

I certify that, on May 26, 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 May 26, 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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