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Case 1:06-cv-00734-RBW Document 26 Filed 12/21/2007 Page 1 of 3

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA











Plaintiffs,












v.


Reverend JOSE MANUEL VEGA FRANQUI,
Individually and as Administrator of the
Estate of VASTHI ZILA MORALES DE VEGA,
et al.











GREAT SOCIALIST PEOPLE’S LIBYAN
ARAB JAMAHIRIYA, et al.











Defendants.
























Case No. 1:06-cv-00734-RBW



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DEFENDANT’S CONSENT MOTION FOR EXTENSION OF TIME

Defendant, Great Socialist People’s Libyan Arab Jamahiriya, by undersigned counsel and

with the consent of Plaintiffs’ counsel, hereby moves pursuant to Fed. R Civ. P. Rule 6 for an

extension of forty-five (45) days for Defendant to file a Reply to Plaintiffs’ Opposition to

Defendant’s Motion to Dismiss on or before January 31, 2008. In support of this Motion,

Defendant states as follows:



1.

On or about December 17, 2007, Plaintiffs filed their Opposition to Defendant’s

Motion to Dismiss. After receiving leave of Court to file an Opposition in excess of the Court’s

page limitations, Plaintiffs filed an approximately sixty-five (65) page Opposition and

accompanying Memorandum of Points and Authorities.



2.

Plaintiffs’ Opposition cites to various secondary sources, government records and

transcripts of Congressional Hearings which must be reviewed by counsel for Defendant. Given

the length of Plaintiffs’ Opposition and numerous citations therein, as well as the current holiday

season, Defendant will require additional time to prepare its Reply to Plaintiffs’ Opposition.

Case 1:06-cv-00734-RBW Document 26 Filed 12/21/2007 Page 2 of 3

3.

This brief extension will not affect any deadline imposed by the Court, as no

deadlines have yet been set in this case. No party will be prejudiced by this brief extension.



4.

Undersigned counsel certifies that in accordance with Local Rule LCvR 7(m), he

has consulted with Plaintiffs’ counsel regarding this request for an extension and Plaintiffs

consent to the relief requested herein.

WHEREFORE, Defendant requests that the Court grant its Consent Motion for an

extension of forty-five (45) days for Defendant to file a Reply to Plaintiffs’ Opposition to

Defendant’s Motion to Dismiss on or before January 31, 2008.











































By:




Respectfully, Submitted,

ECKERT SEAMANS CHERIN
& MELLOTT, LLC







/s/ Mark A. Johnston


Thomas J. Whalen, Esq. (Bar No. 208512)
Mark A. Johnston, Esq. (Bar No. 455764)
1747 Pennsylvania Ave., N.W.,
Twelfth Floor
Washington, D.C. 20006
(202) 659-6600

Counsel for Defendant, Great Socialist People’s
Libyan Arab Jamahiriya

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Case 1:06-cv-00734-RBW Document 26 Filed 12/21/2007 Page 3 of 3

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a copy of the foregoing Consent Motion for Extension of

Time was electronically filed and served, this 21st day of December, 2007, to:












Joshua Ambush
Terri Sneider
The Law Offices of Joshua M. Ambush, LLC
1726 Reisterstown Road Suite 206
Baltimore, MD 21208

/s/ Mark A. Johnston
Mark A. Johnston










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