Case 1:18-cv-01835-PLF Document 52 Filed 10/01/18 Page 1 of 3

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

M.M.M., ON BEHALF OF HIS MINOR
CHILD J.M.A., ET AL.,
Plaintiffs,
v.
JEFFERSON BEAUREGARD SESSIONS,
III, ATTORNEY GENERAL OF THE
UNITED STATES, ET AL.,
Defendants.

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Civil Action No. 1:18-CV-01835 (PLF)

CONSENT MOTION FOR EXTENSION OF TIME
On July 27, 2018, Plaintiffs initially filed a complaint that was assigned Civil Action No:
1:18-CV-01759. Service of the original complaint was perfected on the United States Attorney’s
Office for the District of Columbia on August 2, 2018. On August 3, 2018, Counts I, II, and III
of that complaint were transferred to the Southern District of California, and Count IV was
severed and redocketed as Civil Action No: 1:18-CV-01835. Plaintiffs filed an amended
complaint in this matter on August 8, 2018. See Dkt. No. 31. Accordingly, the earliest a response
to Plaintiffs’ amended complaint would be due is October 1, 2018. See Fed. R. Civ. P.
12(a)(1)(ii); 15(a)(3).
On September 24, 2018, the parties filed a joint status report indicating that the parties
had reached a settlement agreement that would resolve the claims in this action and a related
action also pending before the Court: Dora v. Sessions, Case No. 1:18-cv-01938 (PLF) (D.D.C.).
See Dkt. No. 50. That status report also states that “[i]f approved, the settlement agreement
would require voluntary dismissal of the M.M.M. action currently pending before this Court, as
well as voluntary dismissal of the Dora action.” Id. at 2.

 Case 1:18-cv-01835-PLF Document 52 Filed 10/01/18 Page 2 of 3

Accordingly, pending further action in the Southern District of California regarding the
settlement approval process, counsel for the parties have agreed to allow Defendants an
additional thirty (30) days to respond to Plaintiffs’ amended complaint. Defendants respectfully
request that the Court allow Defendants an extension of time of thirty (30) days to file their
responsive pleading to Plaintiffs’ first amended complaint, such that the responsive pleading
would be due on or before October 31, 2018.
A proposed order is attached.
Dated: October 1, 2018

Respectfully submitted,

JOSEPH H. HUNT
Assistant Attorney General
Civil Division

/s/ Jeffrey S. Robins
JEFFREY S. ROBINS
Assistant Director
U.S. Department of Justice, Civil Division
Office of Immigration Litigation
District Court Section
P.O. Box 868, Washington, DC 20044
Telephone: (202) 616-1246
Facsimile: (202) 305-7000
jeffrey.robins@usdoj.gov

SCOTT G. STEWART
Deputy Assistant Attorney General
AUGUST E. FLENTJE
Special Counsel
WILLIAM C. PEACHEY
Director, Office of Immigration Litigation
District Court Section

Attorneys for Defendants

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 Case 1:18-cv-01835-PLF Document 52 Filed 10/01/18 Page 3 of 3

CERTIFICATE OF SERVICE
I hereby certify that on September 28, 2018, I electronically filed the foregoing CONSENT
MOTION FOR EXTENSION OF TIME with the Clerk of Court by using the CM/ECF system,
which will provide electronic notice and an electronic link to this document to all attorneys of
record.
DATED: September 28, 2018.

By: /s/ Jeffrey S. Robins
JEFFREY S. ROBINS
Assistant Director
United States Department of Justice
Civil Division

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 Case 1:18-cv-01835-PLF Document 52-1 Filed 10/01/18 Page 1 of 1

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

M.M.M., ON BEHALF OF HIS MINOR
CHILD J.M.A., ET AL.,
Plaintiffs,
v.
JEFFERSON BEAUREGARD SESSIONS,
III, ATTORNEY GENERAL OF THE
UNITED STATES, ET AL.,
Defendants.

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Civil Action No. 1:18-CV-01835 (PLF)

[PROPOSED] ORDER ON CONSENT MOTION FOR EXTENSION OF TIME
Before the Court is a Consent Motion for Extension of Time filed by Defendants in this
action. Upon consideration of the motion, and good cause appearing to support the relief
requested, it is ORDERED that the deadline for the filing of Defendants’ responsive pleading is
EXTENDED until October 31, 2018.
Dated: October ___, 2018

Hon. Paul L. Friedman
U.S. District Judge