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IN THE UNITED STATES DISTRICT COURT FOR THE
DISTRICT OF COLUMBIA
WASHINGTON COUNTY, VIRGINIA,
a political subdivision of the Commonwealth of Virginia, County Administration Building 205 Academy Drive Abingdon, Virginia, 24210
Plaintiff, ) ) v.
) ) MICHAEL B. MUKASEY ) Attorney General of the ) United States of America, ) GRACE CHUNG BECKER, ) Acting Assistant Attorney General, ) Civil Rights Division, ) United States Department of Justice, ) Washington, DC, 20530 ) ) Defendants.
) ____________________________________)
Civil Action No. 08-cv-01112
MOTION TO EXTEND TIME TO ANSWER COMPLAINT
Defendants Michael B. Mukasey and Grace Chung Becker, through counsel, respectfully move this three-judge Court, pursuant to Rule 6(b)(1)(A) of the Rules of Civil Procedure, to extend the time to answer by twenty-one days the Complaint filed by Plaintiff Washington County on June 26, 2008. Plaintiff does not oppose the granting of this motion. As grounds for this motion, Defendant would show unto the Court that:
1. Plaintiff Washington County filed this action pursuant to Section 4 of the Voting Rights Act of 1965, as amended, 42 U.S.C. § 1973(b). Plaintiff’s action seeks a
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declaratory judgment from this Court granting the County an exemption from the special remedial provisions of the Voting Rights Act, also known as a bailout.
2. Defendants request the extension of time to continue an investigation on whether it is appropriate to consent to a declaratory judgment in this action, pursuant to Section 4(a)(9) of the Voting Rights Act. Section 4(a)(9) of the Voting Rights Act provides that nothing in the Act “shall prohibit the Attorney General from consenting to an entry of judgment if based upon a showing of objective and compelling evidence by the plaintiff, and upon investigation, he is satisfied that the . . . political subdivision has complied with the requirements of section 4(a)(1).”
3. Counsel for the Plaintiff, J. Gerald Hebert, was contacted prior to the filing of this motion. Plaintiff does not oppose the granting of this motion. WHEREFORE, Plaintiff respectfully prays that this unopposed Motion be granted.
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Respectfully submitted, For the Defendants MUKASEY and BECKER:
MICHAEL B. MUKASEY
Attorney General GRACE CHUNG BECKER Acting Assistant Attorney General JEFFREY A. TAYLOR United States Attorney /s/ Christy McCormick CHRISTOPHER COATES ROBERT POPPER CHRISTY McCORMICK Attorneys, Voting Section Civil Rights Division United States Department of Justice Room 7254 - NWB 950 Pennsylvania Ave., N.W.
Washington, DC 20530
(202) 514-2386
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CERTIFICATE OF SERVICE
I hereby certify that on this 20th day of August 2008, a copy of the foregoing has been electronically filed with the Clerk of the Court using the CM/ECF system, which will electronically send a copy of the same to the following:
J. GERALD HEBERT
Attorney at Law 5019 Waple Lane Alexandria, Virginia 22304
Address of Counsel:
s/Christy A. McCormick Trial Attorney U.S. Department of Justice
Voting Section, Room 7254-NWB Civil Rights Division U.S. Department of Justice 950 Pennsylvania Avenue, NW Washington, DC 20530
(800) 253-3931 (telephone)
(202) 307-3961 (facsimile) E-mail: Christy.McCormick@usdoj.gov
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