2015-06-12 defendant's request for an extension of time to file answer (15cv2627 flores v doj)
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2015-06-12 Defendant's Request for an Extension of Time to File Answer (15cv2627 Flores v DOJ)TRANSCRIPT
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U.S. Department of Justice
United States AttorneyEastern District of New York
271 Cadman Plaza East-7th FloorBrooklyn, New York 11201
June 12, 2015BY ECF
Honorable John GleesonUnited States District JudgeUnited States District CourtEastern District of New York225 Cadman Plaza EastBrooklyn, New York 11201
Re: Louis Flores v. United States Department of JusticeNo. 15-CV-2627 (Gleeson, J.) (Mann, M.J.)
Dear Judge Gleeson:
This Office represents Defendant United States Department of Justice in this action. This Office writes to respectfully request an extension of Defendants time to answer, move, or otherwise respond to the Complaint from June 15, 2015 to July 17, 2015.
Defendant respectfully requests this extension of time to respond because the agency has not yet provided this Office with the relevant documents and/or information that are necessary to formulate a response to the pleadings. The undersigned repeatedly attempted to obtain Plaintiffs consent to this application, but has been unable to reach Plaintiff because the phone number listed on the Complaint is not receiving calls and Plaintiff has not yet responded to the undersigneds e-mails. This is Defendants first request for an extension of time to respond to the Complaint.
Thank you for Your Honors consideration of this request.
Respectfully submitted,
KELLY T. CURRIEActing United States Attorney
By: s/Rukhsanah L. SinghRUKHSANAH L. SINGHAssistant U.S. Attorney (718) [email protected]
Case 1:15-cv-02627-JG-RLM Document 6 Filed 06/12/15 Page 1 of 2 PageID #: 39
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Honorable John GleesonJune 12, 2015Page 2
cc: [via CM/ECF and first-class certified mail]
Louis Flores34-21 77th Street, Apt. #406Jackson Heights, New York 11372Pro se Plaintiff
Case 1:15-cv-02627-JG-RLM Document 6 Filed 06/12/15 Page 2 of 2 PageID #: 40