You're viewing Docket Item 19 from the case BOARD OF COMMISSIONERS OF CHEROKEE COUNTY, KANSAS v. KEMPTHORNE et al. View the full docket and case details.

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Case No. 1:08-cv-00317-RWR
Judge Richard W. Roberts


BOARD OF COMMISSIONERS OF
CHEROKEE COUNTY, KANSAS,


Plaintiff,

v.

DIRK KEMPTHORNE, et al.,


Defendants.







________________________________________







Case 1:08-cv-00317-RWR Document 19 Filed 07/03/2008 Page 1 of 3



IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

PLAINTIFF’S UNOPPOSED MOTION FOR EXTENSION OF TIME

TO RESPOND TO DEFENDANTS’ MOTION TO DISMISS



Plaintiff Board of Commissioners of Cherokee County, Kansas, respectfully

requests an extension of time to file its response to Defendants’ Motion to Dismiss plainitff’s

amended complaint on or before July 28, 2008.





In support of this motion, Plaintiff states as follows:

1.

Defendants’ counsel consents to Plaintiff’s requested extension of time.

Defendant’s counsel requested that Plaintiff ask the Court to set August 11, 2008 as the deadline

for Defendants’ reply brief.





2.

3.

The current deadline to file its reponse is July 8, 2008.

This is Plaintiff’s first request for an extension of time in this action.



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Case 1:08-cv-00317-RWR Document 19 Filed 07/03/2008 Page 2 of 3





4.

The requested additional time will allow Plaintiff’s counsel to meet pre-

existing professional obligations in other matters, adequately review the Administrative Record

Defendants filed on June 23, 2008, and prepare Plaintiff’s responsive brief.



WHEREFORE, Plaintiff respectfully requests the Court grant its request for an

extension of time to file its response to Defendants’ motion to dismiss on or before July 28, 2008,

and to set August 11, 2008 as the deadline for Defendants’ reply brief.

Dated: July 3, 2008





Respectfully submitted,

s/Jonathan L. Abram
Jonathan L. Abram, D.C. Bar No. 389896
[email protected]
Audrey E. Moog, D.C. Bar No. 468600
[email protected]

HOGAN & HARTSON L.L.P.
555 Thirteenth Street, N.W.
Washington, D.C. 20004–1109
(202) 637-5600 (Telephone)
(202) 659-5910 (Facsimile)

David Cooper
[email protected]
FISHER, PATTERSON, SAYLOR & SMITH, LLP
3550 SW 5th Street
Topeka, KS 66601
(785) 232-7761 (Telephone)
(785) 232-6604 (Facsimile)





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Case 1:08-cv-00317-RWR Document 19 Filed 07/03/2008 Page 3 of 3





CERTIFICATE OF SERVICE



I hereby certify that on July 3, 2008, I electronically filed the foregoing Unopposed

Motion for Extension of Time with the Clerk of the District Court using its CM/ECF system,

which provides electronic notification to the CM/ECF participants in this case including:











Amy Tryon
[email protected]













s/Audrey E. Moog
Counsel for Plaintiff Board of Commissioners of
Cherokee County, Kansas


















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Case 1:08-cv-00317-RWR Document 19-2 Filed 07/03/2008 Page 1 of 1



IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA



Case No. 1:08-cv-00317-RWR
Judge Richard W. Roberts


BOARD OF COMMISSIONERS OF
CHEROKEE COUNTY, KANSAS,


Plaintiff,

v.

DIRK KEMPTHORNE, et al.,


Defendants.







________________________________________







GRANTING PLAINTIFF’S UNOPPOSED MOTION FOR EXTENSION OF TIME

TO RESPOND TO DEFENDANTS’ MOTION TO DISMISS

[PROPOSED] ORDER



On consideration of Plaintiff Board of Commissioners of Cherokee County’s

Unopposed Motion for Extension of Time, it is hereby ORDERED that the motion is

GRANTED. Plaintiff’s response to Defendants’ Motion to Dismiss is due on or before July 28,

2008, and Defendants’ reply is due on or before August 11, 2008.


Dated: ________, 2008


























_______________________
Hon. Richard W. Roberts
United States District Judge
District of Columbia



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