Hamilton v. Snow

MOTION for Extension of Time to File Motion for Summary Judgment

D.D.C.August 8, 2007

1 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA ) Gary Hamilton, ) ) Plaintiff, ) Case No.: 05-CV-01549 (RBW) v. ) ) Henry M. Paulson, Jr., ) ) Defendant ) ____________________________________) DEFENDANT’S MOTION FOR EXTENSION OF TIME Pursuant to Fed. R. Civ. P. 6(b), Defendant respectfully requests a two business day extension of time until August 14, 2007, for Defendant to file its Motion for Summary Judgment. Pursuant to Local Rule 7(m), Defendant’s counsel sent a facsimile - the parties’ agreed upon mode of communication - to Plaintiff’s counsel seeking consent for this Motion. At the time of this filing, the undersigned counsel have not heard from Plaintiff’s counsel. There is good cause to grant this Motion. At present, Defendant’s Motion for Summary Judgment is due on August 10, 2007. The undersigned counsel intended to meet this deadline, but other pressing matters prevented the undersigned counsel from completing the summary judgment motion in time. Specifically, the undersigned counsel was out of the office for most of last week for deposition preparation, which took longer than anticipated. Furthermore, the undersigned counsel was required to devote substantial time last week and earlier this week to a discovery matter in yet another class action case. For these reasons, the undersigned counsel was not able to devote the time necessary to preparing the motion for summary judgment in this case. Additional time is needed for the undersigned to complete the motion and circulate it for Case 1:05-cv-01549-RBW Document 41 Filed 08/08/2007 Page 1 of 3 2 client and supervisory review prior to filing it with the Court. For the foregoing reasons, the Court should give Defendant until August 14, 2007, to file its Motion for Summary Judgment. Dated: August 8, 2007. Respectfully Submitted, /s/ Jeffrey A. Taylor JEFFREY A. TAYLOR, D.C. BAR # 498610 United States Attorney /s/ Rudolph Contreras RUDOLPH CONTRERAS, D.C. BAR #434122 Assistant United States Attorney /s/ John C. Truong JOHN C. TRUONG, D.C. BAR #465901 Assistant United States Attorney 555 Fourth Street, N.W. Washington, D.C. 20530 (202) 307-0406 Attorneys for Defendant Case 1:05-cv-01549-RBW Document 41 Filed 08/08/2007 Page 2 of 3 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA ) Gary Hamilton, ) ) Plaintiff, ) Case No.: 05-CV-01549 (RBW) v. ) ) Henry M. Paulson, Jr., ) ) Defendant ) ____________________________________) ORDER Upon consideration of Defendant’s Motion for Extension fo Time and the entire record herein, it is this _______ day of _______, 2007, ORDERED that Defendant’s Motion for an Extension of Time be and is hereby GRANTED; and it is FURTHER ORDERED that Defendant shall have up to and including August 14, 2007, to file its Motion for Summary Judgment. SO ORDERED. _______________________ U.S. District Judge Case 1:05-cv-01549-RBW Document 41 Filed 08/08/2007 Page 3 of 3