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

Filing 94

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

Doc. 94

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA ) ) Plaintiffs, ) ) v. ) Case No. 96-CV-2211 (HHK/JMF) ) RAJ K. MALLICK, ) ) Defendant. ) __________________________________________) RICHARD F. SMITH, et al., MOTION OF PLAINTIFFS RICHARD F. SMITH AND MARINE CARRIERS (USA), INC. TO SHORTEN DEADLINE TO RESPOND TO TEMPORARY RESTRAINING ORDER AND SETTING HEARING DATE Pursuant to LCvR 7(b), Plaintiffs Richard F. Smith and Marine Carriers (USA), Inc. hereby move to shorten the time allowed to respond to Plaintiffs' Motion for a Temporary Restraining Order ("TRO Motion") so that Defendant Raj K Mallick's opposition to the TRO Motion will be due no later than July 13, 2007 and the hearing in this matter will be set for July 16, 2007. Defendant Raj K. Mallick has been notified of the TRO Motion and of this Motion and intends to oppose both motions. In support of this motion, Plaintiffs state as follows: 1. Newly discovered documents reveal that Mr. Mallick has liquidated several major assets just in the last few months, including assets that he transferred shortly after he knew that plaintiffs had become aware of those assets. At the same time, Mr. Mallick continues to maintain that he has insufficient resources to pay the Judgment. 2. For the reasons cited in the Plaintiffs' TRO Motion and in the Memorandum In Support Of (A) Motion Of Plaintiffs Richard F. Smith And Marine Carriers (USA), Inc. For Temporary Restraining Order And (B) Motion For Preliminary Injunction (the

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"Memorandum"), Plaintiffs have serious and substantive reasons for seeking expedited consideration of the TRO Motion. 3. Defendant Raj K. Mallick has been notified of the TRO Motion and has been served with copies of the TRO Motion, the Memorandum, and all of the associated documents. Mr. Mallick will have ample opportunity to respond to the Motion and to be heard on an expedited basis. 4. For all of these reasons, this Court should grant this motion, require Mr. Mallick to serve his opposition to the TRO Motion no later than July 13, 2007, and hear this matter on July 16, 2007, or at the earliest date thereafter that this Court's calendar will allow. Respectfully submitted, _/s/ Joseph G. Cosby_________________________ Thomas Earl Patton (D.C Bar No. 009761) Joseph G. Cosby (D.C. Bar No. 471320) Tighe Patton Armstrong Teasdale P.L.L.C. 1747 Pennsylvania Avenue, N.W., Suite 300 Washington, D.C. 20006-4604 Telephone: [phone] Facsimile: [phone] Cynthia Kaplan Revesman, Esquire RUBENSTEIN, COGAN & QUICK, P.C. 12 S. Summit Avenue, Suite 250 Gaithersburg, Maryland 20877 [phone] Counsel for Plaintiff, Richard F. Smith

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