MASSIE et al v. GOVERNMENT OF THE DEMOCRATIC PEOPLE'S REPUBLIC OF KOREA

Filing 143

MASSIE et al v. GOVERNMENT OF THE DEMOCRATIC PEOPLE'S REPUBLIC OF KOREA

Doc. 143

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF THE DISTRICT OF COLUMBIA MAXINE WRIGHT Plaintiff, v. VERIZON COMMUNICATIONS INC. Defendant. DEFENDANT'S CONSENT MOTION TO EXTEND TIME TO RESPOND TO PLAINTIFF'S AMENDED COMPLAINT Defendant Verizon Communications Inc., by agreement with plaintiff through plaintiff's mediation counsel, respectfully requests the Court to extend defendant's time to answer or otherwise respond to plaintiff's Amended Complaint (dkt. 21) until September 7, 2007. 1. Plaintiff filed her pro se Amended Complaint on December 13, 2006. (Dkt. 21.) Civil Action No. 1:06-cv-01819-HHK

Defendant moved to dismiss on December 21, 2006. (Dkt. 25.) The Court denied the motion to dismiss on August 10, 2007. (Dkt. 45.) Absent an extension, Fed. R. Civ. P. 12(a)(4)(A) requires defendant to answer or otherwise respond to the Amended Complaint by August 24, 2007. 2. The undersigned counsel has recently inherited primary responsibility for this

case from another attorney at Covington & Burling LLP. Counsel accordingly requires additional time to review plaintiff's pleadings and to prepare an informed response to plaintiff's allegations. 3. The Court's August 10, 2007 Order recognized the complexity presented by

plaintiff's pro se allegations, stating that the Court "is endeavoring to appoint counsel for [plaintiff] who may be able to better articulate her grievances in a future submission." (Dkt. 45

Dockets.Justia.com

at 2 n.1.) An extension of the response period will therefore also allow the Court additional time to locate and appoint litigation counsel for plaintiff. 4. Plaintiff, through her mediation counsel, Anne Gbenjo, Esq., consents to

defendant's motion for a 14-day extension. Accordingly, defendant requests that the Court extend defendant's time to answer or otherwise respond to plaintiff's Amended Complaint (dkt. 21) for a period of 14 days, until September 7, 2007.

Respectfully submitted, /s/ Frederick G. Sandstrom Frederick G. Sandstrom (D.C. Bar #495069) Covington & Burling LLP 1201 Pennsylvania Ave., N.W. Washington, DC 20004 Tel.: [phone] Fax: [phone] Attorney for Defendant Verizon Communications Inc. August 21, 2007

2

CERTIFICATE OF SERVICE I certify that on August 21, 2007, I served true and correct copies of the foregoing Consent Motion to Extend Time to Respond to Plaintiff's Amended Complaint on the following individuals: Ms. Maxine Wright 5721 Magnolia Lane Falls Church, VA 22041 Plaintiff (pro se) By Certified Mail Anne Gbenjo, Esq. The Gbenjo Law Group 8449 W. Bellfort Ave., Suite 100 Houston, TX 77071 Plaintiff's Mediation Counsel By Federal Express /s/ Frederick G. Sandstrom