Case 2:18-cv-00939-MJP Document 90 Filed 08/23/18 Page 1 of 4

The Honorable Marsha J. Pechman

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UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON
AT SEATTLE

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No. 2:18-cv-0939 (MJP)
STATE OF WASHINGTON, et al.,

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Plaintiffs,
v.

Defendants’ Partially Opposed Motion to
Extend Time to File Answer

UNITED STATES OF AMERICA, et al.,
Defendants.

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Defendants, the United States of America, et al., by and through undersigned counsel,
move to extend by 30-days the deadline for filing an Answer to the Plaintiffs’ Complaint. See
Fed. R. Civ. P. 12(a)(2); Dkt. No. 1. The requested 30-day extension would make Defendants’
Answer due on Wednesday, September 26, 2018, and would not require the Court to adjust any
other previously established deadlines. On August 21, 2018, Defendants contacted Plaintiffs’
counsel via email to ascertain their position on Defendants’ motion, and Plaintiffs indicated that
they consent to a 14-day extension of the deadline, but opposed Defendants’ request for a longer
30-day extension.
On August 8, 2018, the Court granted Defendants’ Motion to Transfer Venue. Dkt. No.
88. The Court transferred this case to the Southern District of California, finding that there “is
substantial overlap between the States’ claims and those being litigated in [Ms. L v. U.S. ICE,
No. 18-428 (S.D. Cal.)].” Dkt. No. 88. The Court noted that the case was to be assigned to Judge
Sabraw in the Southern District of California, 15-days following the Court’s order, or on August

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DEFENDANTS’ MOTION TO EXTEND TIME TO FILE ANSWER
State of Washington, et al. v. United States, et al.,
Case No. 2:18-cv-00939 (MJP)

U S DEPARTMENT OF JUSTICE
CIVIL DIVISION, OIL-DCS
P O BOX 868 BEN FRANKLIN STATION
WASHINGTON, DC 20044
TELEPHONE: (202) 305-0106
FACSIMILE: (202) 305-7000

 Case 2:18-cv-00939-MJP Document 90 Filed 08/23/18 Page 2 of 4

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23, 2018. Id. Explaining the rationale for granting the Defendants’ motion to transfer, the Court

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noted that “the government must turn all of its efforts to locating and reuniting parents and

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children who have been separated and potentially harmed by this Policy.” Dkt. No. 88. The

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government is actively engaged in the reunification process and compliance with and

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administration of the Ms. L injunction. As the Court noted, “the primary of import of the States’

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case is to reunite families as expeditiously as possible,” dkt. no. 88, and as such, the Defendants’

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request for an extension of time to answer does not harm Plaintiffs. Therefore, in the interests of

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proceeding with this litigation in the most orderly and efficient manner possible, the Court

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should grant Defendants’ motion to extend the time period for Defendants to answer Plaintiffs’

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complaint.
For the reasons stated above, the Defendants respectfully request that the Court extend the
deadline for their Answer to the Complaint by 30-days, through September 26, 2018.

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DATED: August 23, 2018

CHAD A. READLER
Acting Assistant Attorney General

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WILLIAM C. PEACHEY
Director

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EREZ REUVENI
Assistant Director

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NICOLE N. MURLEY
Trial Attorney

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/s/ Nicole N. Murley
NICOLE N. MURLEY
Trial Attorney
JOSHUA PRESS
Trial Attorney
United States Department of Justice
Civil Division
Office of Immigration Litigation

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DEFENDANTS’ MOTION TO EXTEND TIME TO FILE ANSWER
State of Washington, et al. v. United States, et al.,
Case No. 2:18-cv-00939 (MJP)

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U S DEPARTMENT OF JUSTICE
CIVIL DIVISION, OIL-DCS
P O BOX 868 BEN FRANKLIN STATION
WASHINGTON, DC 20044
TELEPHONE: (202) 305-0106
FACSIMILE: (202) 305-7000

 Case 2:18-cv-00939-MJP Document 90 Filed 08/23/18 Page 3 of 4

District Court Section
P.O. Box 868, Ben Franklin Station
Washington, DC 20044
Phone: (202) 616-0473
Nicole.Murley@usdoj.gov

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Attorneys for the United States of America
and the Federal Defendants

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DEFENDANTS’ MOTION TO EXTEND TIME TO FILE ANSWER
State of Washington, et al. v. United States, et al.,
Case No. 2:18-cv-00939 (MJP)

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U S DEPARTMENT OF JUSTICE
CIVIL DIVISION, OIL-DCS
P O BOX 868 BEN FRANKLIN STATION
WASHINGTON, DC 20044
TELEPHONE: (202) 305-0106
FACSIMILE: (202) 305-7000

 Case 2:18-cv-00939-MJP Document 90 Filed 08/23/18 Page 4 of 4

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CERTIFICATE OF SERVICE

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I hereby certify that on August 23, 2018, I electronically transmitted the foregoing

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document to the Clerk’s Office using the U.S. District Court for the Western District of

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Washington’s Electronic Document Filing System (ECF), which will serve a copy of this

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document upon all counsel of record.

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By: /s/ Nicole N. Murley
NICOLE N. MURLEY

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DEFENDANTS’ MOTION TO EXTEND TIME TO FILE ANSWER
State of Washington, et al. v. United States, et al.,
Case No. 2:18-cv-00939 (MJP)

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U S DEPARTMENT OF JUSTICE
CIVIL DIVISION, OIL-DCS
P O BOX 868 BEN FRANKLIN STATION
WASHINGTON, DC 20044
TELEPHONE: (202) 305-0106
FACSIMILE: (202) 305-7000

 Case 2:18-cv-00939-MJP Document 90-1 Filed 08/23/18 Page 1 of 2

The Honorable Marsha J. Pechman

UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON
AT SEATTLE
STATE OF WASHINGTON, et al.,
No. 2:18-cv-0939 (MJP)
Plaintiffs,
v.
UNITED STATES OF AMERICA, et al.,

[PROPOSED] ORDER ON
DEFENDANTS’ MOTION TO
EXTEND TIME TO FILE
ANSWER

Defendants,
Before the Court is Defendants’ Motion to extend time to file answer. For the reasons stated
in the Defendants’ Motion, the Court finds that good cause supports the requested 30-day
extension. Accordingly, Defendants’ deadline to file an Answer to the Complaint is extended
through September 26, 2018.

Dated: August ______, 2018

[PROPOSED] ORDER GRANTING
DEFENDANTS’ MOTION TO RENOTE
Case No. 2:18-cv-0939 (MJP)

_____________________________
HONORABLE MARSHA J. PECHMAN
United States District Judge

U.S. DEPARTMENT OF JUSTICE
CIVIL DIVISION, OIL-DCS
P.O. BOX 868 BEN FRANKLIN
STATION
WASHINGTON, DC 20044
TELEPHONE: (202) 616-0473
FACSIMILE: (202) 305-7000

 Case 2:18-cv-00939-MJP Document 90-1 Filed 08/23/18 Page 2 of 2

Presented by:
CHAD A. READLER
Acting Assistant Attorney General
WILLIAM C. PEACHEY
Director
EREZ REUVENI
Assistant Director
NICOLE N. MURLEY
Trial Attorney
JOSHUA S. PRESS
Trial Attorney
United States Department of Justice
Civil Division
Office of Immigration Litigation
District Court Section
P.O. Box 868, Ben Franklin Station
Washington, DC 20044
Phone: (202) 305-0106
joshua.press@usdoj.gov
Attorneys for the United States of America
and the Federal Defendants

[PROPOSED] ORDER GRANTING
DEFENDANTS’ MOTION TO RENOTE
Case No. 2:18-cv-0939 (MJP)

U.S. DEPARTMENT OF JUSTICE
CIVIL DIVISION, OIL-DCS
P.O. BOX 868 BEN FRANKLIN
STATION
WASHINGTON, DC 20044
TELEPHONE: (202) 616-0473
FACSIMILE: (202) 305-7000