Be eNom □□□ Maen ween MS oe ets nited States Attorney Southern District of New York 86 Chambers Street New York, New York 10007 September 2, 2022 REQUEST GRANTED. VIA ECF The time for the Government to respond to the Complaint is extended to □□□ Hon. Lewis J. Liman 21, 2022. The Initial Pretrial Conference is rescheduled to November 1, 202 United States District Judge 11:00AM. Parties are directed to dial into the Court's teleconference lin United States District Court 888-251-2909 and use access code 2123101. Parties are reminded to joi 500 Pearl Street submit, by one week prior to the conference, a proposed Case Management | New York, New York 10007 and Scheduling Order consistent with the Court's individual practices. Re: Lin Chen v. Mayorkas, et al., 22 Civ. 3646 (LIL) 7/1/2072, SooRPERED. é FP, Dear Judge Liman: United States District Judge This Office represents the government in this action in which the plaintiff seeks an order compelling U.S. Citizenship and Immigration Services (“USCIS”) to adjudicate an Application to Register Permanent Residence or Adjust Status (Form I-485) and two Refugee/Asylee Relative Petitions (Forms I-730). On behalf of the government, I write respectfully to request a forty-five- day extension of the time to respond to the complaint (7.e., from September 6, 2022 to October 21, 2022). In addition, I respectfully request that the mitial pretrial conference presently scheduled for September 22, 2022, be rescheduled for a date during the week of October 31, 2022, or thereafter (with a corresponding extension of time for the preconference submission). I respectfully request this extension because USCIS approved the Form I-485 and both Forms I-730, rendering moot the plaintiffs claims.! See Compl. §§ 2, 15. I recently mailed to the plaintiff a copy of the approvals, a cover letter listing my contact information, and a proposed stipulation and order of dismissal, and need to allow time for the plaintiff to respond. This is the government’s second request for an extension of the deadline to respond to the complaint; the Court granted the prior request. See ECF No. 9. The government has been unable to obtain a response from the plaintiff regarding whether the plaintiff consents to the extension and adjournment request given that the complaint provides no email address or telephone number.”

I thank the Court for its consideration of this letter.

‘Tn the immigration and naturalization context, courts have dismissed cases as moot where the agency, such as USCIS, to which the plaintiff has applied provides the relief sought in the complaint prior to the court’s adjudication.” Jinbin Wu v. Johnson, No. 16 Civ. 4523 (KAM),

, at *4 (E.D.N.Y. Feb. 27, 2018); see also Li v. Napolitano, No. 08 Civ. 7353 (JGK),

, at *3 (S.D.N.Y. July 30, 2009) (similar). ? The mailing address in the petition appears to correspond to a storefront mailbox center and is also the exact mailing address for the litigants in approximately sixteen other cases recently filed in this District.

Respectfully submitted,

DAMIAN WILLIAMS United States Attorney

By: s/ Jacqueline Roman JACQUELINE ROMAN Special Assistant United States Attorney 86 Chambers Street, 3rd Floor New York, New York 10007 Telephone: (347) 714-3363 E-mail: [email protected] Attorney for Defendants

cc: Counsel of record (via ECF)