Unopposed MOTION for Extension of Time to File Response/Reply as to [12] Cross MOTION for Summary Judgment by UNITED STATES DEPARTMENT OF JUSTICE (Attachments: # (1) Text of Proposed Order)(Oldham, Nicholas)
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Page 1 IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
DEMOCRATIC NATIONAL
COMMITTEE,
Plaintiff,
v.
Civil Action No. 07-712 (ESH)
UNITED STATES DEPARTMENT
OF JUSTICE,
Defendant.
UNOPPOSED MOTION FOR EXTENSION OF TIME FOR DEFENDANT TO
FILE REPLY IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT AND
OPPOSITION TO PLAINTIFF’S CROSS-MOTION FOR SUMMARY JUDGMENT
Defendant, by undersigned counsel, respectfully moves pursuant to Rule 6 of the Federal
Rules of Civil Procedure for a seven-day extension of time through and including March 6, 2008
to file its Reply in Support of Defendant’s Motion for Summary Judgment and Opposition to
Plaintiff’s Cross-Motion for Summary Judgment. In support of this Motion, Defendant states as
follows:
1.
Pursuant to the parties’ Joint Briefing Schedule filed on January 11, 2008 (dkt. no.
9) and the Court’s January 11, 2008 Minute Order, Defendant filed its Motion for Summary
Judgment on January 24, 2008 (dkt. no. 11), and Plaintiff filed its Opposition and Cross-Motion
for Summary Judgment on February 14, 2008 (dkt. no. 12). Defendant’s Reply and Opposition
are due on or before February 28, 2008.
2.
Due to significant scheduling difficulties that were unanticipated at the time the
parties set the briefing schedule, undersigned counsel needs an additional seven days to preparePage 2 Defendant’s Reply and Opposition and obtain the necessary approval to file the Reply and
Opposition.
3.
Pursuant to Local Rule 7(m), undersigned counsel has conferred with counsel for
Plaintiff. Plaintiff does not oppose the relief requested in this Motion.
Accordingly, Defendant respectfully requests that the Court grant an extension of time
through and including Thursday, March 6, 2008 for Defendant to file its Reply and Opposition.
Respectfully submitted,
Jeffrey S. Bucholtz
Acting Assistant Attorney General
JEFFREY A. TAYLOR
United States Attorney
Washington, D.C. 20003
ELIZABETH J. SHAPIRO
Assistant Director
Federal Programs Branch
/s/ Nicholas A. Oldham
Nicholas A. Oldham (D.C. Bar No. 484113)
Trial Attorney
U.S. Department of Justice
Civil Division, Federal Programs Branch
Mailing Address
P.O. Box 883
Washington, D.C. 20044
Delivery Address
20 Massachusetts Ave., N.W., Rm. 6134
Washington, D.C. 20001
Tel: (202) 514-3367
Fax: (202) 616-8470
nicholas.oldham@usdoj.gov
Attorneys for Defendant
Date: February 26, 2008
2Page 3 IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
DEMOCRATIC NATIONAL
COMMITTEE,
Plaintiff,
v.
UNITED STATES DEPARTMENT
OF JUSTICE,
Civil Action No. 07-712 (ESH)
Defendant.
[PROPOSED] ORDER
HAVING CONSIDERED Defendant’s Unopposed Motion for Extension of Time to File
Reply in Support of its Motion for Summary Judgment and Opposition to Plaintiff’s CrossMotion for Summary Judgment, it is hereby this ____ day of February 2008, ORDERED that
the Defendant shall file its Reply and Opposition on or before March 6, 2008.
__________________________________
ELLEN SEGAL HUVELLE
UNITED STATES DISTRICT JUDGE
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PlainSite Cover Page
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Case 1:07-cv-00712-ESH
Document 13
Filed 02/26/2008
Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
DEMOCRATIC NATIONAL
COMMITTEE,
Plaintiff,
v.
Civil Action No. 07-712 (ESH)
UNITED STATES DEPARTMENT
OF JUSTICE,
Defendant.
UNOPPOSED MOTION FOR EXTENSION OF TIME FOR DEFENDANT TO
FILE REPLY IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT AND
OPPOSITION TO PLAINTIFF’S CROSS-MOTION FOR SUMMARY JUDGMENT
Defendant, by undersigned counsel, respectfully moves pursuant to Rule 6 of the Federal
Rules of Civil Procedure for a seven-day extension of time through and including March 6, 2008
to file its Reply in Support of Defendant’s Motion for Summary Judgment and Opposition to
Plaintiff’s Cross-Motion for Summary Judgment. In support of this Motion, Defendant states as
follows:
1.
Pursuant to the parties’ Joint Briefing Schedule filed on January 11, 2008 (dkt. no.
9) and the Court’s January 11, 2008 Minute Order, Defendant filed its Motion for Summary
Judgment on January 24, 2008 (dkt. no. 11), and Plaintiff filed its Opposition and Cross-Motion
for Summary Judgment on February 14, 2008 (dkt. no. 12). Defendant’s Reply and Opposition
are due on or before February 28, 2008.
2.
Due to significant scheduling difficulties that were unanticipated at the time the
parties set the briefing schedule, undersigned counsel needs an additional seven days to prepare
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Case 1:07-cv-00712-ESH
Document 13
Filed 02/26/2008
Page 2 of 2
Defendant’s Reply and Opposition and obtain the necessary approval to file the Reply and
Opposition.
3.
Pursuant to Local Rule 7(m), undersigned counsel has conferred with counsel for
Plaintiff. Plaintiff does not oppose the relief requested in this Motion.
Accordingly, Defendant respectfully requests that the Court grant an extension of time
through and including Thursday, March 6, 2008 for Defendant to file its Reply and Opposition.
Respectfully submitted,
Jeffrey S. Bucholtz
Acting Assistant Attorney General
JEFFREY A. TAYLOR
United States Attorney
Washington, D.C. 20003
ELIZABETH J. SHAPIRO
Assistant Director
Federal Programs Branch
/s/ Nicholas A. Oldham
Nicholas A. Oldham (D.C. Bar No. 484113)
Trial Attorney
U.S. Department of Justice
Civil Division, Federal Programs Branch
Mailing Address
P.O. Box 883
Washington, D.C. 20044
Delivery Address
20 Massachusetts Ave., N.W., Rm. 6134
Washington, D.C. 20001
Tel: (202) 514-3367
Fax: (202) 616-8470
nicholas.oldham@usdoj.gov
Attorneys for Defendant
Date: February 26, 2008
2
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Case 1:07-cv-00712-ESH
Document 13-2
Filed 02/26/2008
Page 1 of 1
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
DEMOCRATIC NATIONAL
COMMITTEE,
Plaintiff,
v.
UNITED STATES DEPARTMENT
OF JUSTICE,
Civil Action No. 07-712 (ESH)
Defendant.
[PROPOSED] ORDER
HAVING CONSIDERED Defendant’s Unopposed Motion for Extension of Time to File
Reply in Support of its Motion for Summary Judgment and Opposition to Plaintiff’s CrossMotion for Summary Judgment, it is hereby this ____ day of February 2008, ORDERED that
the Defendant shall file its Reply and Opposition on or before March 6, 2008.
__________________________________
ELLEN SEGAL HUVELLE
UNITED STATES DISTRICT JUDGE
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