Sellmon v. Reilly et al

MOTION for Extension of Time to File Defendants' Statement of Genuine Issues in Response to Plaintiffs' Joint and Individual Statments of Facts

D.D.C.February 20, 2008

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA __________________________________________ ) TONY R. SELLMON, et al., ) ) Plaintiffs, ) ) ) Civil Action No. 06-1650 (ESH) v. ) (ECF) ) EDWARD F. REILLY, JR., et al., ) ) Defendants. ) __________________________________________) DEFENDANTS’ MOTION TO EXTEND TIME TO FILE A STATEMENT OF GENUINE ISSUES IN RESPONSE TO PLAINTIFFS’ JOINT AND INDIVIDUAL STATEMENTS OF MATERIAL FACTS Pursuant to Fed. R. Civ. P. 6(b)(1), Defendants respectfully request an enlargement of time up to and including February 21, 2008, to file a Statement of Genuine Issues in Response to Plaintiffs’ Joint and Individual Statement of Material Facts. In support of this motion, Defendants state the following: 1. A short while ago, Defendants filed their Motion for Judgment on the Pleadings or in the Alternative to Transfer and Opposition to Plaintiffs’ Motion for Summary Judgment. 2. Defendants’ Statement of Genuine Issues in Response to Plaintiffs’ Joint and Individual Statements of Material Facts is substantially complete. However, in light of the technicalities involved, the undersigned seeks this brief extension to consult with Agency Counsel. 3. The undersigned does not anticipate any further requests for extensions with regard to this specific request. Case 1:06-cv-01650-ESH Document 56 Filed 02/20/2008 Page 1 of 3 2 4. Pursuant to LCvR 7(m), the undersigned sent opposing counsel an email seeking consent after the close of business and understandably has not heard back. 5. This request should be minimally inconvenient and prejudicial to the parties whose pleadings will be due five days from the dates currently set by the court. WHEREFORE, Defendants respectfully request that this enlargement be granted. A minute order is respectfully requested. February 20, 2008 Respectfully submitted, _/s/_______________________________________ JEFFREY A. TAYLOR, D.C. BAR # 498610 United States Attorney /s/ RUDOLPH CONTRERAS, D.C. BAR # 434122 Assistant United States Attorney _/s/_______________________________________ KENNETH ADEBONOJO Assistant United States Attorney Judiciary Center Building 555 4th Street, N.W. - Civil Division Washington, D.C. 20530 (202) 514-7157 (202) 514-8780 (facsimile) Case 1:06-cv-01650-ESH Document 56 Filed 02/20/2008 Page 2 of 3 CERTIFICATE OF SERVICE I certify that on this 20th day of February 2008, I caused the foregoing Defendants’ Motion to Enlarge Time to File a Statement of Genuine Issues in Response to Plaintiffs’ Joint and Individual Statement of Material Facts to be served on Plaintiffs’ attorney, Jason D. Wallach, Esq., via the Court’s Electronic Case Filing system. _/s/_______________________________ KENNETH ADEBONOJO Assistant United States Attorney Judiciary Center Building 555 4th Street, N.W. - Civil Division Washington, D.C. 20530 (202) 514-7157 (202) 514-8780 (facsimile) Case 1:06-cv-01650-ESH Document 56 Filed 02/20/2008 Page 3 of 3