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    STEINBUCH v. CUTLER - Document No. 6

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    MOTION for Extension of Time to File Response/Reply as to 5 MOTION to Dismiss the Complaint by ROBERT STEINBUCH. (Attachments: # 1 Proposed Order)(Rosen, Jonathan) 1:2005cv00970 District Of Columbia District Court

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    STEINBUCH v. CUTLER - Document No. 6

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    MOTION for Extension of Time to File Response/Reply as to 5 MOTION to Dismiss the Complaint by ROBERT STEINBUCH. (Attachments: # 1 Proposed Order)(Rosen, Jonathan) 1:2005cv00970 District Of Columbia District Court

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    MOTION for Extension of Time to File Response/Reply as to 5 MOTION to Dismiss the Complaint by ROBERT STEINBUCH. (Attachments: # 1 Proposed Order)(Rosen, Jonathan) 1:2005cv00970 District Of Columbia District Court

    Copyright:

    Public Domain
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    61 views2 pages

    STEINBUCH v. CUTLER - Document No. 6

    Uploaded by

    Justia.com
    MOTION for Extension of Time to File Response/Reply as to 5 MOTION to Dismiss the Complaint by ROBERT STEINBUCH. (Attachments: # 1 Proposed Order)(Rosen, Jonathan) 1:2005cv00970 District Of Columbia District Court

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    of 2

    STEINBUCH v. CUTLER Doc.

    6
    Case 1:05-cv-00970-PLF-JMF Document 6 Filed 07/29/2005 Page 1 of 2

    UNITED STATES DISTRICT COURT


    FOR THE DISTRICT OF COLUMBIA
    __________________________________________
    STEINBUCH )
    )
    Plaintiff, )
    )
    v. ) CASE No. 01:05-CV-00970 (PLF)
    )
    CUTLER )
    )
    Defendant. )
    __________________________________________)

    PLAINTIFF’S UNOPPOSED MOTION AND MEMORANDUM


    IN SUPPORT OF AN EXTENSION OF TIME IN WHICH
    TO RESPOND TO DEFENDANT’S MOTION TO DISMISS

    Plaintiff hereby moves for an extension of time to and including September 15,

    2005, in which to respond to Defendant’s Motion to Dismiss. Our response is currently

    due on August 8, 2005. This is our first request for an extension of time. On July 28,

    2005, Plaintiff’s counsel conferred with counsel for Defendant, concerning the current

    motion. Defendant’s counsel consented to the enlargement. Plaintiff had previously

    consented to Defendant’s enlargement to file the Motion to Dismiss.

    Plaintiff’s counsel is requesting the additional time to accommodate previously-

    scheduled work obligations and the unavailability of Plaintiff during part of this period

    due to the scheduled surgery of a family member and other work obligations.

    Accordingly, for the reasons set forth above, we respectfully request that the

    Court grant this extension of time, until September 15, 2005, in which to file our response

    to Defendant’s Motion to Dismiss.

    Dated: July 28, 2005

    Dockets.Justia.com
    Case 1:05-cv-00970-PLF-JMF Document 6 Filed 07/29/2005 Page 2 of 2

    Respectfully Submitted,

    /Jonathan Rosen/
    Jonathan Rosen (NY0046)
    1200 Gulf Blvd., #1506
    Clearwater, FL 33767
    (908) 759-1116
    Attorney for Plaintiff

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