Sellmon v. Reilly et al

MOTION for Extension of Time to File Summary Judgment and Opposition to Plaintiffs' Motion for Summary Judgment

D.D.C.February 13, 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 DISPOSITIVE MOTION AND OPPOSITION TO PLAINTIFFS’ MOTION FOR SUMMARY JUDGMENT Pursuant to Fed. R. Civ. P. 6(b)(1), Defendants respectfully request an enlargement of time up to and including February 15, 2008, to file a dispositive motion and opposition to Plaintiffs’ Motion for Summary Judgment. In support of this motion, Defendants state the following: 1. Defendants’ dispositive motion and opposition to Plaintiffs’ Motion for Summary Judgment is due today, February 13, 2008. 2. Defendants’ motion and opposition is substantially complete but responses to a few inquiries to Agency Counsel are still outstanding. 3. The undersigned should have said responses by tomorrow but is asking for an extension until February 15, 2008, out of an abundance of caution. 4. Pursuant to LCvR 7(m), the undersigned sent opposing counsel an email a short while ago but has not heard back. Case 1:06-cv-01650-ESH Document 51 Filed 02/13/2008 Page 1 of 3 5. This request should be minimally inconvenient and prejudicial to the parties as it adds only two days to each of the current due dates. WHEREFORE, Defendants respectfully request that this enlargement be granted. A minute order is respectfully requested. February 13, 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 51 Filed 02/13/2008 Page 2 of 3 CERTIFICATE OF SERVICE I certify that on this 13th day of February 2008, I caused the foregoing Defendants’ Motion to Enlarge Time to File a Dispositive Motion and Opposition to Plaintiffs’ Motion for Summary Judgment 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 51 Filed 02/13/2008 Page 3 of 3