UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

________________________________
                                )
WILLIAM THOMAS,                 )
                                )
         Plaintiff.             )
                                )                 
               v.               )   Civil Action No. 99-330 {GK}
                                )
OFFICER DAVID LOMBARDI, et al., )
                                )
         Defendants.            )
________________________________)

PLAINTIFF'S UNOPPOSED MOTION FOR EXTENSION
OF TIME TO OPPOSE DEFENDANTS' MOTION TO DISMISS

Plaintiff moves the Court for an extension of time, to and including August 9,1999, in which to submit plaintiff's opposition to defendants' motion to dismiss. Counsel for defendants consents to the granting of this motion and requests an extension of time to file defendants' reply to and including September 7, 1999. In support of this motion, plaintiff relies on the accompanying memorandum.

Respectfully submitted,

ALISA A.WILKINS.
Alisa A. Wilkins, D.C. Bar #440880
Daniel M. Schember, D.C. Bar #237180
Gaffney & Schember, P.C.
1666 Connecticut Avenue, N.W., Ste. 225
Washington, D.C. 20009
202 / 328 - 2244

Counsel for Plaintiff


UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

________________________________
                                )
WILLIAM THOMAS,                 )
                                )
         Plaintiff.             )
                                )                 
               v.               )   Civil Action No. 99-330 {GK}
                                )
OFFICER DAVID LOMBARDI, et al., )
                                )
         Defendants.            )
________________________________)

 

MEMORANDUM IN SUPPORT OF PLAINIFF'S
UNOPPOSED MOTION FOR EXTENSION OF TIME TO OPPOSE
DEFENDANTS' MOTION TO DISMISS

Plaintiffs opposition to defendants' Motion to Dismiss currently is due July 6.1999. Due to the numerous issues of law and fact raised by defendants' lengthy motion and plaintiffs counsel's unusually heavy schedule of pleadings and court appearances at the present time, plaintiff needs an extension of time to August 9, 1999 in order to prepare and file a proper response.

By telephone conference on June 23, 1999, counsel for plaintiff obtained the consent of Stacy Ludwig, counsel for defendants, to the granting of plaintiffs motion, and agreed to consent to defendants' request for an extension of time to file defendants' reply to and including September 7, 1999. Defendants will need the requested extension of time to file their reply after plaintiff submits his opposition on August 9, 1999 because defendants' counsel will be away from her office the week of August 16, 1999 on previously scheduled annual leave, and from August 25-27, 1999 for a work-related conference.

The mutually agreed extensions of time for plaintiff to file his opposition and for defendants to file their reply should be granted.

 

Respectfully submitted,

ALISA A.WILKINS.
Alisa A. Wilkins, D.C. Bar #440880
Daniel M. Schember, D.C. Bar #237180
Gaffney & Schember, P.C.
1666 Connecticut Avenue, N.W., Ste. 225
Washington, D.C. 20009
202 / 328 - 2244

Counsel for Plaintiff

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

________________________________
                                )
WILLIAM THOMAS,                 )
                                )
         Plaintiff.             )
                                )                 
               v.               )   Civil Action No. 99-330 {GK}
                                )
OFFICER DAVID LOMBARDI, et al., )
                                )
         Defendants.            )
________________________________)

 

ORDER

This matter having come before the Court on plaintiffs unopposed motion for an extension of time to oppose defendants' motion to dismiss, it is this ____ day of
_____________________. 1999.

ORDERED, that plaintiffs motion is granted. Plaintiff shall have until August 9, 1999 to oppose defendants' motion to dismiss; and it is further

ORDERED, that defendants shall have until September 7, 1999 to file a reply memorandum of points and authorities in support of their motion to dismiss.

________________________
Gladys Kessler
United States District Judge

Copies to:

Stacy M. Ludwig
Assistant United States Attorney
Judiciary Center Building
555 4th Street, N.W., Room 10-120
Washington, D.C. 20001

Daniel M. Schember
Alisa A. Wilkins
Gaffney & Schember, P.C.
1666 Connecticut Ave., N.W.
Suite 225
Washington D.C. 20009

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a copy of the foregoing Unopposed Motion for Extension of Time to Oppose Defendants' Motion to Dismiss was served, via first class mail, postage prepaid, this 6 day of July, 1999 to:

Stacy M. Ludwig
Assistant United States Attorney
Judiciary Center Building
555 Fourth Street, N.W., Room 10-120
Washington, DC 20001

ALISA A. WILKINS
Alisa A. Wilkins