Becker, et al v. District of Columbia, et alMOTION for Extension of Time to Complete DiscoveryD.D.C.June 17, 2004UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA __________________________________________ : ALLIANCE FOR GLOBAL JUSTICE, et al., : : Plaintiffs, : : v. : Case No. 01-00811 (PLF)(JMF) : DISTRICT OF COLUMBIA, et al., : : Defendants. : __________________________________________: MOTION OF DEFENDANTS DISTRICT OF COLUMBIA, CHIEF CHARLES H. RAMSEY, AND TERRENCE W. GAINER FOR AN ENLARGEMENT OF TIME FOR THE PARTIES TO COMPLETE DEPOSITION DISCOVERY Defendants, District of Columbia (“District”), Chief Charles H. Ramsey, and Terrence W. Gainer respectfully move this Court for an order, pursuant to Fed. R. Civ. P 6(b)(1), enlarging the time within which the parties may complete deposition discovery in this matter for a period of 90 days, to and including September 28, 2004. The defendants seek this enlargement to take the depositions of plaintiffs, which defendants jointly noticed to commence on May 27, 2004. Pursuant to LCvR 7.1(m), undersigned counsel has communicated repeatedly with counsel for the other parties in this matter and has attempted to confer with them by telephone before filing this motion to discuss with opposing counsel, in a good faith effort to determine whether there is any opposition to the relief sought, and if so, how to narrow the areas of disagreement. To that end, the District Defendants have transmitted a draft proposed order to all counsel and requested their consent and/or requested revisions to the order and the relief it would provide, if granted. In response the United States has expressed its consent to the relief sought by this motion and further authorized the District Defendants to represent that the relief sought is "requested by 2 Federal and District Defendants." The District Defendants have attempted to confer with plaintiffs’ counsel in accordance with LCvR 7.1(m) without success. Based upon earlier communications with plaintiffs’ counsel regarding the relief requested, District Defendants do not anticipate plaintiffs’ consent to the relief requested herein.1 The Court is respectfully referred to the memorandum of points and authorities submitted in support of this motion, which is incorporated by reference. Respectfully submitted, ROBERT J. SPAGNOLETTI Attorney General for the District of Columbia GEORGE C. VALENTINE Deputy Attorney General Civil Litigation Division /s/ Richard S. Love RICHARD S. LOVE  Chief, Equity Section I Civil Litigation Division /s/ Thomas L. Koger THOMAS L. KOGER  MARTHA J. MULLEN  Senior Litigation Counsel Equity Section I 441-4th St., N.W., Sixth Floor South Washington, D.C. 20001 (202) 724-6610 Attorneys for Defendants District of Columbia, Chief Charles H. Ramsey, and Terrence W. Gainer 1 As of this filing, plaintiffs have not yet responded to the District Defendants’ voicemail or commented upon the proposed order transmitted to plaintiffs on June 17, 2004 to accurately inform them of the relief sought hereby. In light of the remedy sought and of the status of deposition discovery, as reflected in the supporting memorandum of points and authorities, undersigned counsel believes that the filing of this motion should not be delayed further awaiting plaintiffs’ response.