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

_____________________________________

BIZUAYEHU YLIMA BAYEH,

Plaintiff,

v.

UNITED STATES CITIZENSHIP AND 

IMMIGRATION SERVICES, et al.,

Defendants.

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

DEFENDANTS’ 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. 

Pursuant to Federal Rule of Civil Procedure 6(b)(1)(A), Defendants respectfully move the 

Court for a 45-day extension of time to answer or otherwise respond to the complaint, 

which would extend the response deadline from May 26, 2022 to July 11, 2022. The

reason for this extension request is that, on May 23, 2022, USCIS issued a request for 

evidence to Plaintiff in connection with the Form I-485. A response to the request for 

evidence is due by August 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 

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

response period provided in a request for evidence exceed twelve weeks . . . .”).1 Upon 

receipt of the response to the request for evidence, USCIS will resume processing the 

Form I-485. USCIS expects that, by July 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 45-day extension of time to answer or otherwise 

respond to Plaintiff’s complaint, from May 26, 2022 to July 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

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 23 and 24, 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 May 24, 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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