Defendants’ Third 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

_____________________________________ 

BIZUAYEHU YLIMA BAYEH,

Plaintiff, 

v.

UNITED STATES CITIZENSHIP AND 

IMMIGRATION SERVICES, et al., 

Defendants.

Civil Action No. 3:22-cv-01008-C 

DEFENDANTS’ THIRD UNOPPOSED MOTION FOR AN 

EXTENSION OF TIME TO ANSWER OR OTHERWISE RESPOND 

In this case, Plaintiff Bizuayehu Ylima Bayeh seeks a writ of mandamus to compel 

U.S. Citizenship and Immigration Services (USCIS) to adjudicate a Form I-485, 

“Application to Register Permanent Residence or Adjust Status.” See Doc. 1 at 2. On 

May 31, 2022 and July 11, 2022, the Court granted Defendants’ unopposed motions for, 

respectively, a 45-day and a 30-day extension of time to answer or otherwise respond to 

the complaint, due to a request for evidence that USCIS issued to Plaintiff in connection 

with the Form I-485 and USCIS’s processing of Plaintiff’s response to that request. See

Docs. 8–11. 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 10, 2022 to October 11, 2022. The reason for this third extension 

request is that, on July 26, 2022, USCIS issued a notice scheduling Plaintiff for an 

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

interview on August 25, 2022. USCIS expects that, by October 11, 2022, it will have 

either completed adjudicating the Form 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. Plaintiff does not oppose this extension request. 

Therefore, Defendants respectfully move the Court for a 60-day extension of time to 

answer or otherwise respond to Plaintiff’s complaint, from August 10, 2022 to October 

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

Certificate of Conference

I certify that, on July 27, 2022, I conferred with Plaintiff’s counsel regarding this 

motion, and counsel stated that Plaintiff does not oppose the motion. 

 /s/ Lisa R. Hasday 

Lisa R. Hasday 

Assistant United States Attorney

 

Certificate of Service 

 On July 27, 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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