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Case 1:07-cv-01495-HHK Document 12 Filed 03/19/2008 Page 1 of 6

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA











____________________________________
)

ACT NOW TO STOP WAR AND END
)
RACISM COALITION, et al.,
)
)

)
)
)
)
)
)

)
____________________________________)






DISTRICT OF COLUMBIA,



Plaintiffs,




Defendant.











v.





















Civil Action No.07-1495 (HHK)





DEFENDANT’S CONSENT MOTION TO AMEND THE SCHEDULE

Pursuant to Fed. R. Civ. P. 6(b)(1) and 7(b), defendant the District of Columbia hereby

moves this Honorable Court to amend the schedule in this matter and allow an additional two

weeks for the District to file its Reply. The District’s Memorandum of Points and Authorities in

support hereof is attached hereto and incorporated by reference herein. A proposed Order also is

attached hereto.

Pursuant to LCvR 7(m), the undersigned counsel discussed the instant motion with

opposing counsel, who consented to the relief requested herein.

WHEREFORE, the District respectfully requests that this Honorable Court:

A. Grant the District’s Consent Motion to Amend the Schedule, and

B. Grant the District such other and further relief as the nature of its cause may require.







DATE: March 19, 2008




























Respectfully submitted,

PETER J. NICKLES
Interim Attorney General for the District of Columbia

GEORGE C. VALENTINE
Deputy Attorney General, Civil Litigation Division

Case 1:07-cv-01495-HHK Document 12 Filed 03/19/2008 Page 2 of 6






































































































/s/ Ellen A. Efros


ELLEN A. EFROS, D.C. Bar No. 250746
Chief, Equity Section I
441 Fourth Street, N.W., 6th Floor South
Washington, D.C. 20001
Telephone: (202) 442-9886
Facsimile: (202) 727-0431


ANDREW J. SAINDON, D.C. Bar No. 456987
Assistant Attorney General
Equity I Section
441 Fourth Street, N.W., 6th Floor South
Washington, D.C. 20001
Telephone: (202) 724-6643
Facsimile: (202) 727-0431
[email protected]

/s/ Andrew J. Saindon

2

Case 1:07-cv-01495-HHK Document 12 Filed 03/19/2008 Page 3 of 6



UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA







____________________________________
)

ACT NOW TO STOP WAR AND END
)
RACISM COALITION, et al.,
)
)

)
)
)
)
)
)

)
____________________________________)






DISTRICT OF COLUMBIA,



Plaintiffs,




Defendant.













v.





















Civil Action No.07-1495 (HHK)





MEMORANDUM OF POINTS AND AUTHORITIES

IN SUPPORT OF

THE DISTRICT’S CONSENT MOTION TO

AMEND THE SCHEDULE

Defendant the District of Columbia (“the District”), by and through undersigned counsel,



respectfully submits this Memorandum of Points and Authorities in Support of its Consent

Motion to Amend the Schedule, pursuant to Fed. R. Civ. P. 6(b)(1) and 7(b). A proposed Order

is attached hereto.

In support of the instant consent motion, and for its good cause shown, the District states

as follows:

1. On February 6, 2008, the District filed its Motion to Dismiss in the instant matter.

2. Plaintiffs subsequently sought and received the District’s consent to enlarge

plaintiffs’ time to file their opposition to the District’s dispositive motion. The Court granted the

requested enlargement, and plaintiffs filed their opposition on March 14, 2008.

3. Pursuant to LCvR 7(d), the District’s Reply is due on or before March 21, 2008.



Case 1:07-cv-01495-HHK Document 12 Filed 03/19/2008 Page 4 of 6



4. Fed. R. Civ. P. 6(b)(1) permits an enlargement of time, such as that requested herein,

“if request therefor is made before the expiration of the period originally prescribed . . .” for

cause shown.

5. For its good cause shown, the District states that the press of other business has

deprived counsel of the time necessary to prepare an appropriate Reply in light of plaintiffs’

opposition.

6. This enlargement is not sought for any improper purpose, but to insure that the

District is able to prepare an adequate submission for the Court. No party will be prejudiced, and

the brief extension requested here will have no effect on any other deadlines. Moreover,

opposing counsel consented to the relief requested herein.

7. Based on the above, the District respectfully requests that this Honorable Court enter

an order pursuant to Fed. R. Civ. P. 6(b)(1), to amend the schedule such that the District’s Reply

is due on or before April 4, 2008.




















DATE: March 19, 2008











































































Respectfully submitted,

PETER J. NICKLES
Interim Attorney General for the District of Columbia

GEORGE C. VALENTINE
Deputy Attorney General, Civil Litigation Division







/s/ Ellen A. Efros


ELLEN A. EFROS, D.C. Bar No. 250746
Chief, Equity Section I
441 Fourth Street, N.W., 6th Floor South
Washington, D.C. 20001
Telephone: (202) 442-9886
Facsimile: (202) 727-0431


ANDREW J. SAINDON, D.C. Bar No. 456987
Assistant Attorney General

/s/ Andrew J. Saindon





- 2 -

Case 1:07-cv-01495-HHK Document 12 Filed 03/19/2008 Page 5 of 6







































Equity I Section
441 Fourth Street, N.W., 6th Floor South
Washington, D.C. 20001
Telephone: (202) 724-6643
Facsimile: (202) 727-0431
[email protected]

- 3 -



____________________________________
)

ACT NOW TO STOP WAR AND END
)
RACISM COALITION, et al.,
)
)

)
)
)
)
)
)

)
____________________________________)






DISTRICT OF COLUMBIA,



Plaintiffs,




Defendant.











v.















ORDER









Civil Action No.07-1495 (HHK)





Case 1:07-cv-01495-HHK Document 12 Filed 03/19/2008 Page 6 of 6



UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA







Upon consideration of the District’s Consent Motion to Amend the Schedule, the

Memorandum of Points and Authorities in Support thereof, opposing counsel’s consent thereto,

the entire record herein, and it appearing that the relief should be granted, it is hereby:



ORDERED, that the District’s Consent Motion to Amend the Schedule be, and hereby is,

GRANTED, and it is

FURTHER ORDERED, that the District’s Reply is due on or before April 4, 2008

SO ORDERED.

DATE: ___________________
























___________________________________
HENRY H. SULLIVAN
United States District Judge





____________________________________
)

ACT NOW TO STOP WAR AND END
)
RACISM COALITION, et al.,
)
)

)
)
)
)
)
)

)
____________________________________)






DISTRICT OF COLUMBIA,



Plaintiffs,




Defendant.











v.















ORDER









Civil Action No.07-1495 (HHK)





Case 1:07-cv-01495-HHK Document 12-2 Filed 03/19/2008 Page 1 of 1



UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA







Upon consideration of the District’s Consent Motion to Amend the Schedule, the

Memorandum of Points and Authorities in Support thereof, opposing counsel’s consent thereto,

the entire record herein, and it appearing that the relief should be granted, it is hereby:



ORDERED, that the District’s Consent Motion to Amend the Schedule be, and hereby is,

GRANTED, and it is

FURTHER ORDERED, that the District’s Reply is due on or before April 4, 2008

SO ORDERED.




DATE: ___________________






















___________________________________
HENRY H. SULLIVAN
United States District Judge