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

_____________________________________

REDIET W. SHIFERAW, et al.,

Plaintiffs,

v.

UNITED STATES CITIZENSHIP AND 

IMMIGRATION SERVICES, et al.,

Defendants.

Civil Action No. 3:22-cv-00479-S

DEFENDANTS’ UNOPPOSED MOTION FOR AN

EXTENSION OF TIME TO ANSWER OR OTHERWISE RESPOND

In this case, Plaintiffs Rediet W. Shiferaw and Million H. Hailemichael seek a writ 

of mandamus to compel U.S. Citizenship and Immigration Services (USCIS) to 

adjudicate Forms I-485, “Application to Register Permanent Residence or Adjust Status.” 

See Doc. 1 at 2. Pursuant to Federal Rule of Civil Procedure 6(b)(1)(A), Defendants 

respectfully move the Court for a 30-day extension of time to answer or otherwise 

respond to the complaint, which would extend the response deadline from May 6, 2022 to 

June 6, 2022. The reason for this extension request is that, on April 13, 2022, USCIS 

issued two requests for evidence to Plaintiffs. The responses to the requests for evidence 

are due by July 11, 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 

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

provided in a request for evidence exceed twelve weeks . . . .”).1 Upon receipt of the 

responses to the requests for evidence, USCIS will resume processing the Forms I-485. 

USCIS expects that, by June 6, 2022, it will have either completed adjudicating the 

Forms I-485, 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 30-day extension of time to answer or otherwise respond to Plaintiffs’ 

complaint, from May 6, 2022 to June 6, 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 April 14, 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 April 14, 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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