WAKA LLC v. DCKICKBALL et al

Filing 18

WAKA LLC v. DCKICKBALL et al

Doc. 18

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA WAKA, LLC, A Virginia Limited Liability Company, Plaintiff-Counterclaim Defendant, v. DC KICKBALL, and CARTER RABASA, Individually ) ) ) ) ) ) ) ) Civil Action No. 1:06cv00984 EGS ) ) ) ) ) ) ) ) ) ) ) )

Defendants-Counterclaim Plaintiffs.

DEFENDANTS' UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE OPPOSITION TO PLAINTIFF'S 12(b)(6) MOTION TO DISMISS COUNTERCLAIMS AND/OR 12(c) MOTION FOR JUDGMENT ON THE PLEADINGS DISMISSING COUNTERCLAIM Defendants DC Kickball and Carter Rabasa (collectively referred to as "Defendants") hereby move to extend the time to file their opposition to Plaintiff's 12(b)(6) Motion to Dismiss Counterclaims and/or 12(c) Motion for Judgment on the Pleadings Dismissing Counterclaim ("Motion to Dismiss"). Plaintiff WAKA, LLC

("Plaintiff") does not oppose this Motion. In support of the Motion, Defendants would show as follows: 1. 2. 2007. Plaintiff filed its Motion to Dismiss on January 9, 2007. Defendants' opposition to the Motion to Dismiss is due on January 23,

Dockets.Justia.com

3.

Plaintiff agrees to an extension of time for Defendants to file their

opposition to the Motion to Dismiss until and including January 26, 2007. 4. Defendants therefore respectfully request that the Court extend time for

Defendants to file their opposition to the Motion to Dismiss until and including January 26, 2007. A proposed order is being filed concurrently with this Motion. DATED: January 22, 2007 NOVAK DRUCE & QUIGG LLP /s/ Melvin A. Todd By: Melvin A. Todd (DC Bar No. 481782) 1000 Louisiana Street Fifty Third Floor Houston, Texas 77002 Phone: [phone] Facsimile: 713-456-2836 Attorney for Defendants

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CERTIFICATE OF CONFERENCE Pursuant to LCvR 7(m), counsel for Defendants conferred with opposing counsel on January 22, 2007 and this Motion is unopposed.

DATED: January 22, 2007

NOVAK DRUCE & QUIGG LLP /s/ Melvin A. Todd

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CERTIFICATE OF SERVICE This certifies that a true and correct copy of the foregoing DEFENDANTS' UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE OPPOSITION TO PLAINTIFF'S 12(b)(6) MOTION TO DISMISS COUNTERCLAIMS AND/OR 12(c) MOTION FOR JUDGMENT ON THE PLEADINGS DISMISSING COUNTERCLAIM was served on Plaintiff's counsel via First Class Mail and Facsimile Transmission on January 22, 2007 as follows: Thomas M. Dunlap, Esq. Daniel L. Grubb, Esq. Dunlap, Grubb & Weaver, P.C. 199 Liberty St., SW Leesburg, VA 20175-2715 Facsimile: 703-777-3656 /s/ Melvin A. Todd Of Novak Druce & Quigg LLP

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