Page 1 IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
RONALD ADAMS
Plaintiff,
v.
RAND CONSTRUCTION CORPORATION
Defendant.
)
)
)
)
)
)
)
)
)
)
)
No. 1:07-cv-01874(RCL)
DEFENDANT’S CONSENT MOTION TO EXTEND
TIME TO RESPOND TO PLAINTIFF’S COMPLAINT
Defendant Rand Construction Corporation (“Defendant”) by its undersigned attorneys,
hereby moves this Court for an extension of time to respond to Plaintiff’s Complaint on or by
January 11, 2007. In support of this Motion, Defendant states as follows:.
Defendant was served with Plaintiff’s Complaint on December 3, 2007, thus
requiring it to respond to the Complaint by December 24, 2007..
Given the holiday season and to allow Defendant sufficient time to investigate
and assess the allegations contained in the Complaint, Defendant requests additional time, until
January 11, 2007, to respond to the Complaint..
Granting this requested extension of time will not unduly delay this case, in which
no scheduling order has been entered..
Plaintiff’s counsel consented to this requested extension on December 18, 2007.
.
For all of the above reasons, it is appropriate to extend the time for Defendant to
respond to Plaintiff’s Complaint until January 11, 2007.Page 2 WHEREFORE, Defendant respectfully requests that the Court extend the time for it to
respond to Plaintiff’s Complaint to January 11, 2007.
Respectfully submitted,
RAND CONSTRUCTION CORPORATION
By: /s/ Charles F. Walters
Charles F. Walters, Esq. # 444529
Elisabeth Moriarty-Ambrozaitis # 488848
SEYFARTH SHAW LLP Connecticut Avenue, N.W.
Suite 500
Washington, D.C. 20006-4004
(202) 463-2400
(202) 828-5393 (facsimile)
Its Attorneys
Dated: December 19, 2007Page 3 CERTIFICATE OF SERVICE
I hereby certify that on this 19th day of December, 2007, I served, by first class mail,
postage prepaid, a copy of the foregoing Defendant’s Consent Motion to Extend Time to
Respond to Plaintiff’s Complaint upon:
Daniel S. Kozma, Esq.
The Law Office of Daniel S. Kozma, Esq. L Street, N.W., Suite 245
Washington, DC 20037
/s/ Elisabeth Moriarty-Ambrozaitis
Elisabeth Moriarty-AmbrozaitisPage 4 IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
RONALD ADAMS
Plaintiff,
v.
RAND CONSTRUCTION CORPORATION
Defendant.
)
)
)
)
)
)
)
)
)
)
)
No. 1:07-cv-01874(RCL)
ORDER
Upon consideration of Defendant’s Consent Motion for an Extension of Time to Answer
Plaintiff’s Complaint, in the above-captioned matter, it is hereby ORDERED that Defendant’s
Motion is GRANTED, and it is,
FURTHER ORDERED that Defendant’s time to respond to Plaintiff's Complaint be
extended to January 11, 2007.
SO ORDERED.
__________________________________
HON. JUDGE ROYCE C. LAMBERTH
DC1 30214529.1
PDF Page 1
PlainSite Cover Page
PDF Page 2
Case 1:07-cv-01874-RCL
Document 3
Filed 12/19/2007
Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
RONALD ADAMS
Plaintiff,
v.
RAND CONSTRUCTION CORPORATION
Defendant.
)
)
)
)
)
)
)
)
)
)
)
No. 1:07-cv-01874(RCL)
DEFENDANT’S CONSENT MOTION TO EXTEND
TIME TO RESPOND TO PLAINTIFF’S COMPLAINT
Defendant Rand Construction Corporation (“Defendant”) by its undersigned attorneys,
hereby moves this Court for an extension of time to respond to Plaintiff’s Complaint on or by
January 11, 2007. In support of this Motion, Defendant states as follows:
1.
Defendant was served with Plaintiff’s Complaint on December 3, 2007, thus
requiring it to respond to the Complaint by December 24, 2007.
2.
Given the holiday season and to allow Defendant sufficient time to investigate
and assess the allegations contained in the Complaint, Defendant requests additional time, until
January 11, 2007, to respond to the Complaint.
4.
Granting this requested extension of time will not unduly delay this case, in which
no scheduling order has been entered.
5.
Plaintiff’s counsel consented to this requested extension on December 18, 2007.
6.
For all of the above reasons, it is appropriate to extend the time for Defendant to
respond to Plaintiff’s Complaint until January 11, 2007.
PDF Page 3
Case 1:07-cv-01874-RCL
Document 3
Filed 12/19/2007
Page 2 of 3
WHEREFORE, Defendant respectfully requests that the Court extend the time for it to
respond to Plaintiff’s Complaint to January 11, 2007.
Respectfully submitted,
RAND CONSTRUCTION CORPORATION
By: /s/ Charles F. Walters
Charles F. Walters, Esq. # 444529
Elisabeth Moriarty-Ambrozaitis # 488848
SEYFARTH SHAW LLP
815 Connecticut Avenue, N.W.
Suite 500
Washington, D.C. 20006-4004
(202) 463-2400
(202) 828-5393 (facsimile)
Its Attorneys
Dated: December 19, 2007
PDF Page 4
Case 1:07-cv-01874-RCL
Document 3
Filed 12/19/2007
Page 3 of 3
CERTIFICATE OF SERVICE
I hereby certify that on this 19th day of December, 2007, I served, by first class mail,
postage prepaid, a copy of the foregoing Defendant’s Consent Motion to Extend Time to
Respond to Plaintiff’s Complaint upon:
Daniel S. Kozma, Esq.
The Law Office of Daniel S. Kozma, Esq.
2120 L Street, N.W., Suite 245
Washington, DC 20037
/s/ Elisabeth Moriarty-Ambrozaitis
Elisabeth Moriarty-Ambrozaitis
PDF Page 5
Case 1:07-cv-01874-RCL
Document 3-2
Filed 12/19/2007
Page 1 of 1
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
RONALD ADAMS
Plaintiff,
v.
RAND CONSTRUCTION CORPORATION
Defendant.
)
)
)
)
)
)
)
)
)
)
)
No. 1:07-cv-01874(RCL)
ORDER
Upon consideration of Defendant’s Consent Motion for an Extension of Time to Answer
Plaintiff’s Complaint, in the above-captioned matter, it is hereby ORDERED that Defendant’s
Motion is GRANTED, and it is,
FURTHER ORDERED that Defendant’s time to respond to Plaintiff's Complaint be
extended to January 11, 2007.
SO ORDERED.
__________________________________
HON. JUDGE ROYCE C. LAMBERTH
DC1 30214529.1
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