WILLIAM THOMAS, Plaintiff v. Civil Action No. 97-0712 (TFH) CHRISTIAN STANTON, et al., Defendants
The defendants, by and through counsel, respectfully move this Court pursuant to Rule 6(b), Fed. R. Civ. P., to enlarge the time within which to answer or otherwise respond to the complaint in this matter. Defendants request that the time be extended one business day to and including July 28, 1997. Defendants' counsel contacted plaintiff's counsel about this motion, but she could not reach her in time for filing today.
A response to the complaint is due on July 25, 1997. Defendants fully anticipated that they would be able to submit a response to the complaint today; however, defendants' counsel has not obtained all of the information that she needs from the agency. She has Spoken with the agency counsels about this matter Several times and again today, and agency counsel promised that the undersigned would receive that information by July 28, 1997. Accordingly, based on the foregoing, defendants need one additional business to Submit a response in this matter.
Wherefore, based on the foregoing, the defendants respectfully request that the time for answering or otherwise responding to the complaint be extended to and including July 28, 1997. [1]
Respect fully Submitted,
(signed by SMH)
MARY LOU LEARY, DC Bar #3357485
United States Attorney
Stacy M. Ludwig
STACY M. LUDWIG, D.C. Bar, # 445719
Assistant United States Attorney
[1 Defendants respectfully reserve all defenses available to them under Fed. R. Civ. P. 12(b)(6), including qualified immunity.]
I hereby certify that the foregoing copy of the motion for enlargement of time HAS been Sent via first class mail, this 25th day of July 1997, addressed to:
Daniel M. Schember, Esq.
Alisa Wilkins, Esq.
Gaffney & Schember
1666 Connecticut Avenue, N.W. Suite 225
Washington D.C. 20009
Stacy M. Ludwig
Assistant United States Attorney
Judiciary Center Building
555 Fourth St., N.W.
Washington, D.C. 20001
(202) 514-7147
WILLIAM THOMAS, Plaintiff v. Civil Action No. 97-0712 (TFH) CHRISTIAN STANTON, et al., Defendants
UPON CONSIDERATION of the defend ants' motion for enlargement of time and for good cause shown, it is this day of ________, 1997,
ORDERED, that the defendants' motion should be and is hereby granted, and it is further
ORDERED, that defendant shall have until July 28, 1997, within which to answer or other wise respond to the complaint.
UNITED STATES DISTRICT JUDGE
Stacy M. Ludwig
Assistant United States Attorney
Judiciary Center Building
555 4th Street, N.W., Room 10-806
Washington, D.C. 20001
Daniel M. Schember, Esq.
Alisa Wilkins, Esq.
Gaffney & Schember
1666 Connecticut Avenue, N.W. Suite 225
Washington D.C. 20009