Joint MOTION for Extension of Time to File Answer re [1] Complaint by RAND CONSTRUCTION CORPORATION (Attachments: # (1) Text of Proposed Order)(Moriarty-Ambrozaitis, Elisabeth)
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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)
JOINT MOTION FOR EXTENSION OF TIME FOR DEFENDANT
TO RESPOND TO PLAINTIFF’S COMPLAINT
Plaintiff Ronald Adams and Defendant Rand Construction Corporation (collectively the
“Parties”), by and through undersigned counsel, hereby move this Court for a forty-five (45) day
extension of time for Rand Construction Corporation to respond to Plaintiff’s Complaint, such
that Defendant’s response would be due on or before March 31, 2008. In support of this Motion,
the Parties state as follows:.
The Parties have reached an agreement in principle to fully settle this matter.
.
The Parties will need additional time to agree on a final written settlement
agreement and release, and to fully afford Plaintiff his statutory rights in connection with his
release of claims, including but not limited to the provisions of 29 U.S.C. § 626(f)..
In order to allow the Parties sufficient time to accomplish the above, to avoid
unnecessary pleading by Defendant, and to avoid any additional extensions of time in this matter,
the Parties hereby request that deadline for Defendant to respond to Plaintiff’s Complaint be
extended forty-five (45) days, until March 31, 2008.
DC1 30223115.1Page 2 Granting this requested extension of time will not unduly delay this case, in which
no scheduling order has been entered.
WHEREFORE, the Parties respectfully request that the Court extend the time for it to
respond to Plaintiff’s Complaint to March 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
RONALD ADAMS
By: /s/ Daniel S. Kozma
Daniel S. Kozma, Esq., # 940874
The Law Office of Daniel S. Kozma, Esq. L Street, N.W., Suite 245
Washington, DC 20037-969-2223
Dated: February 14, 2008
DC1 30223115.1Page 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)
ORDER
Upon consideration of the Parties’ Joint Motion for an Extension of Time for Defendant
to Respond to Plaintiff’s Complaint in the above-captioned matter, it is hereby ORDERED that
the Parties’ Motion is GRANTED, and it is,
FURTHER ORDERED that Defendant’s time to respond to Plaintiff's Complaint be
extended to March 31, 2008.
SO ORDERED.
__________________________________
HON. ROYCE C. LAMBERTH
DC1 30223115.1
PDF Page 1
PlainSite Cover Page
PDF Page 2
Case 1:07-cv-01874-RCL
Document 11
Filed 02/14/2008
Page 1 of 2
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)
JOINT MOTION FOR EXTENSION OF TIME FOR DEFENDANT
TO RESPOND TO PLAINTIFF’S COMPLAINT
Plaintiff Ronald Adams and Defendant Rand Construction Corporation (collectively the
“Parties”), by and through undersigned counsel, hereby move this Court for a forty-five (45) day
extension of time for Rand Construction Corporation to respond to Plaintiff’s Complaint, such
that Defendant’s response would be due on or before March 31, 2008. In support of this Motion,
the Parties state as follows:
1.
The Parties have reached an agreement in principle to fully settle this matter.
2.
The Parties will need additional time to agree on a final written settlement
agreement and release, and to fully afford Plaintiff his statutory rights in connection with his
release of claims, including but not limited to the provisions of 29 U.S.C. § 626(f).
3.
In order to allow the Parties sufficient time to accomplish the above, to avoid
unnecessary pleading by Defendant, and to avoid any additional extensions of time in this matter,
the Parties hereby request that deadline for Defendant to respond to Plaintiff’s Complaint be
extended forty-five (45) days, until March 31, 2008.
DC1 30223115.1
PDF Page 3
Case 1:07-cv-01874-RCL
6.
Document 11
Filed 02/14/2008
Page 2 of 2
Granting this requested extension of time will not unduly delay this case, in which
no scheduling order has been entered.
WHEREFORE, the Parties respectfully request that the Court extend the time for it to
respond to Plaintiff’s Complaint to March 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
RONALD ADAMS
By: /s/ Daniel S. Kozma
Daniel S. Kozma, Esq., # 940874
The Law Office of Daniel S. Kozma, Esq.
2120 L Street, N.W., Suite 245
Washington, DC 20037
202-969-2223
Dated: February 14, 2008
DC1 30223115.1
PDF Page 4
Case 1:07-cv-01874-RCL
Document 11-2
Filed 02/14/2008
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 the Parties’ Joint Motion for an Extension of Time for Defendant
to Respond to Plaintiff’s Complaint in the above-captioned matter, it is hereby ORDERED that
the Parties’ Motion is GRANTED, and it is,
FURTHER ORDERED that Defendant’s time to respond to Plaintiff's Complaint be
extended to March 31, 2008.
SO ORDERED.
__________________________________
HON. ROYCE C. LAMBERTH
DC1 30223115.1
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