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 SECOND 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 a twenty (20) day extension of time to respond to Plaintiff’s
Complaint, such that Defendant’s response would be due on or by January 31, 2008. In support
of this Motion, Defendant states as follows:.
Defendant was served with Plaintiff’s Complaint on December 3, 2007.
.
Due to the holiday season and to allow Defendant sufficient time to investigate
and assess the allegations contained in the Complaint, Defendant requested additional time to
respond to Plaintiff’s Complaint..
On December 20, 2007, the Court granted Defendant’s request for an extension of
time to respond until January 11, 2008..
The parties are now engaged in settlement discussions. The parties wish to fully
explore the possibility of settlement prior to proceeding with the litigation of this matter..
As such, Defendant respectfully requests an additional twenty (20) days, until
January 31, 2008, to respond to Plaintiff’s Complaint.Page 2 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 January 10, 2008.
.
For all of the above reasons, it is appropriate to extend the time for Defendant to
respond to Plaintiff’s Complaint until January 31, 2008.
WHEREFORE, Defendant respectfully requests that the Court extend the time for it to
respond to Plaintiff’s Complaint to January 31, 2008.
Respectfully submitted,
RAND CONSTRUCTION CORPORATION
By: /s/ Elisabeth Moriarty-Ambrozaitis
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: January 10, 2008Page 3 CERTIFICATE OF SERVICE
I hereby certify that on this 10th day of January 2008, I electronically served a copy of the
foregoing Defendant’s Second 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 Second Consent Motion for an Extension of Time to
Respond to 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 31, 2008.
SO ORDERED.
__________________________________
HON. ROYCE C. LAMBERTH
DC1 30215957.1
PDF Page 1
PlainSite Cover Page
PDF Page 2
Case 1:07-cv-01874-RCL
Document 7
Filed 01/10/2008
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 SECOND 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 a twenty (20) day extension of time to respond to Plaintiff’s
Complaint, such that Defendant’s response would be due on or by January 31, 2008. In support
of this Motion, Defendant states as follows:
1.
Defendant was served with Plaintiff’s Complaint on December 3, 2007.
2.
Due to the holiday season and to allow Defendant sufficient time to investigate
and assess the allegations contained in the Complaint, Defendant requested additional time to
respond to Plaintiff’s Complaint.
3.
On December 20, 2007, the Court granted Defendant’s request for an extension of
time to respond until January 11, 2008.
4.
The parties are now engaged in settlement discussions. The parties wish to fully
explore the possibility of settlement prior to proceeding with the litigation of this matter.
5.
As such, Defendant respectfully requests an additional twenty (20) days, until
January 31, 2008, to respond to Plaintiff’s Complaint.
PDF Page 3
Case 1:07-cv-01874-RCL
6.
Document 7
Filed 01/10/2008
Page 2 of 3
Granting this requested extension of time will not unduly delay this case, in which
no scheduling order has been entered.
7.
Plaintiff’s counsel consented to this requested extension on January 10, 2008.
8.
For all of the above reasons, it is appropriate to extend the time for Defendant to
respond to Plaintiff’s Complaint until January 31, 2008.
WHEREFORE, Defendant respectfully requests that the Court extend the time for it to
respond to Plaintiff’s Complaint to January 31, 2008.
Respectfully submitted,
RAND CONSTRUCTION CORPORATION
By: /s/ Elisabeth Moriarty-Ambrozaitis
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: January 10, 2008
PDF Page 4
Case 1:07-cv-01874-RCL
Document 7
Filed 01/10/2008
Page 3 of 3
CERTIFICATE OF SERVICE
I hereby certify that on this 10th day of January 2008, I electronically served a copy of the
foregoing Defendant’s Second 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 7-2
Filed 01/10/2008
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 Second Consent Motion for an Extension of Time to
Respond to 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 31, 2008.
SO ORDERED.
__________________________________
HON. ROYCE C. LAMBERTH
DC1 30215957.1
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