Opinion
Case No. 2:12-cv-02167
03-12-2013
BORIS ANGUELOV AVRAMSKI, Plaintiff, v. UNITED STATES, et al., Respondents.
DANIEL G. BOGDEN United States Attorney Carlos A. Gonzalez Assistant United States Attorney STUART F. DELERY Principal Deputy Assistant Attorney General Civil Division DAVID J. KLINE Office of Immigration Litigation Director, District Court Section SAMUEL P. GO Office of Immigration Litigation Senior Litigation Counsel, District Court Section JOHN J. W. INKELES Office of Immigration Litigation U.S. Department of Justice, Civil Division Trial Attorney, District Court Section Counsel for Defendants
DANIEL G. BOGDEN
United States Attorney
District of Nevada
Nevada Bar No. 2137
CARLOS A. GONZALEZ
Assistant United States Attorney
333 Las Vegas Blvd. So., #5000
Las Vegas, Nevada 89101
Ph: (702) 388-6336
Fax: (702) 388-6787
E-mail: Carlos.Gonzalez2@usdoj.gov
Attorneys for the United States.
UNOPPOSED MOTION FOR 30 DAY
EXTENSION OF TIME TO ANSWER,
PLEAD, OR OTHERWISE RESPOND
TO PLAINTIFF'S COMPLAINT FOR
WRIT OF MANDAMUS AND
DECLARATORY RELIEF
The United States of America by and through Daniel G. Bogden, United States Attorney for the District of Nevada, and Carlos A. Gonzalez, Assistant United States Attorney, without waiving any defenses that may be available in this case, for the reasons set forth below, the Defendants move this Court for an unopposed 30-day extension of time, from March 11, 2013, to and including April 10, 2013, by which to answer, plead, or otherwise respond to Boris Anguelov Avramski's ("Plaintiff") Petition for Writ of Mandamus and Declaratory Relief ("Complaint"). . . . . . .
Plaintiff has petitioned the Court, inter alia, for a writ of mandamus compelling the Defendants to grant his naturalization application. Defendants have been diligently preparing to answer, plead, or otherwise respond to Plaintiff's Complaint by March 11, 2013. In preparation to answer, plead, or otherwise respond, Defendants have been coordinating with agency counsel, gathering documents, and determining their defenses. Simultaneously, the parties to this action are exploring avenues to resolve this litigation.
As the parties seek to resolve the dispute giving rise to this litigation, counsel for Defendants requests an additional 30 days to answer, plead, or otherwise respond to Plaintiff's Complaint. Should the parties not be able to resolve this matter, Defendants expect to be in position to answer, plead, or otherwise respond to the Plaintiff's Complaint by April 10, 2013.
Counsel for the Defendants has conferred with counsel for Plaintiff, Peter L. Ashman, who has no opposition to this request for an extension of time. . . . . . . . . . . . . . . . . . . . . . . . .
Accordingly, Defendants request an extension of time, from March 11, 2013, to and including April 10, 2013, by which to answer, plead, or otherwise respond to Plaintiff's Complaint.
Respectfully submitted,
DANIEL G. BOGDEN
United States Attorney
Carlos A. Gonzalez
Assistant United States Attorney
OF COUNSEL: STUART F. DELERY
Principal Deputy Assistant Attorney General
Civil Division
DAVID J. KLINE
Office of Immigration Litigation
Director, District Court Section
SAMUEL P. GO
Office of Immigration Litigation
Senior Litigation Counsel, District Court Section
JOHN J. W. INKELES
Office of Immigration Litigation
U.S. Department of Justice, Civil Division
Trial Attorney, District Court Section
Counsel for Defendants
IT IS SO ORDERED.
_________________
UNITED STATES MAGISTRATE JUDGE