REPUBLIC OF PERU v. YALE UNIVERSITY

Filing 19

Consent MOTION for Extension of Time to Respond to Defendant's Motion to Dismiss and for Defendant to File its Reply Brief by REPUBLIC OF PERU (Attachments: # 1 Text of Proposed Order)(Scheideman, Edward)

REPUBLIC OF PERU v. YALE UNIVERSITY

Doc. 19

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA REPUBLIC OF PERU Plaintiff, v. YALE UNIVERSITY Defendant. ) ) ) ) ) ) ) ) ) )

Case No. 1:08-cv-02109-HHK

CONSENT MOTION FOR EXTENSION OF TIME FOR PLAINTIFF TO RESPOND TO DEFENDANT'S MOTION TO DISMISS AND FOR DEFENDANT TO FILE ITS REPLY BRIEF Pursuant to Federal Rule of Civil Procedure 6(b), Plaintiff, Republic of Peru ("Peru"), with the Consent of Defendant, Yale University ("Yale"), respectfully requests that the Court extend the time, by fourteen (14) days, for: (1) Peru to respond to Defendant's Motion to Dismiss; and (2) Yale to file its Reply Memorandum. In support of this Consent Motion, Peru states: 1. Peru was served with Defendant's Motion to Dismiss on May 21, 2009. The

parties agreed that Yale would be allowed an additional fourteen (14) days to file its Motion to Dismiss in light of the allegations and issues involved in this litigation. 2. In light of that extension, and the nature of the issues at hand, both parties request

that the time for Peru to file its Response to Yale's Motion to Dismiss and for Yale to file its Reply Memorandum be similarly extended for fourteen (14) days. 3. Given this limited extension, Peru's Response to Yale's Motion to Dismiss will

now be due on or before June 15, 2009, and Yale's Reply Memorandum will be due on or before July 9, 2009.

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Dockets.Justia.com

4.

Defendant consents to this motion.

WHEREFORE, for the foregoing reasons, Plaintiff, Republic of Peru, with the consent of Defendant, respectfully requests that its Motion for Extension of Time be granted.

Respectfully submitted, May 27, 2009 /s/ William P. Cook (D.C. Bar No. 465006) Edward S. Scheideman (D.C. Bar No. 475128) Cristina E. Antelo (D.C. Bar No. 500124) DLA PIPER LLP (US) 500 8th Street, N.W. Washington, D.C. 20004 Tel: [phone] Fax: [phone] Ileana M. Blanco Christina E. Ponig DLA Piper LLP (US) 600 Travis Avenue Suite 1700 Houston, Texas 77002 Tel: [phone] Fax: [phone] Attorneys for the Republic of Peru

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA REPUBLIC OF PERU Plaintiff, v. YALE UNIVERSITY Defendant. ) ) ) ) ) ) ) ) ) )

Case No. 1:08-cv-02109-HHK

CERTIFICATE OF SERVICE I hereby certify that on this 27th day of May, 2009, Plaintiff's Consent Motion For Extension of Time For Plaintiff to Respond to Defendant's Motion to Dismiss And For Defendant to File Its Reply Brief was served, via electronic mail, on the following: Jonathan M. Freiman Jeffrey R. Babbin, Esq. R. Scott Greathead (pro hac vice) Wiggin and Dana LLP One Century Tower P.O. Box 1832 New Haven, Connecticut 06508-1832 Attorneys for Yale University

/s/ Edward S. Scheideman

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