CHAMBER OF COMMERCE OF THE UNITED STATES OF AMERICA v. SERVIN et al

Filing 25

MOTION for Extension of Time to File Response/Reply as to 15 MOTION to Dismiss and Plaintiff's Opposition Thereto by MORGAN GOODWIN, JOHN and JANE DOES NOS. 1-20, SARAH MURPHY, JACQUES SERVIN, DAVID SIEVERS, SUPPORT AND COMMITMENT, INC., IGOR VAMOS (Attachments: # 1 Text of Proposed Order)(Corn-Revere, Robert)

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA

CHAMBER OF COMMERCE OF THE
UNITED STATES OF AMERICA,
Plaintiff,
v.
JACQUES SERVIN, et al.
Defendants.

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Case No. 09-CV-02014-RWR

DEFENDANTS’ UNOPPOSED MOTION TO EXTEND TIME TO FILE REPLY BRIEF
AND MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT THEREOF
Defendants Jacques Servin, Igor Vamos, Support and Commitment, Inc., David Sievers,
Morgan Goodwin, Sarah Murphy and John and Jane Does No. 1-20 (collectively “Defendants”),
through undersigned counsel and pursuant to Rule 6(b)(1)(a) of the Federal Rules of Civil
Procedure, respectfully move this Court, unopposed, for an order extending the time by which
Defendants must file a reply to Plaintiff’s opposition to defendants’ motion to dismiss in the
above-captioned action to and including Friday, February 19, 2010.
1.

Defendants were served with Plaintiff’s opposition to Defendants’ motion to

dismiss on February 5, 2010. Pursuant to an order entered by this Court on January 15, 2010,
Defendants’ reply is due on Monday, February 15, 2010.
2.

Defendants seek an extension of the deadline to file their reply up to and

including February 19, 2010.
3.

Defendants request this extension due to the unprecedented and severe winter

weather conditions in the Washington, D.C. As the Court is aware, such conditions have cause

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the closure of federal government offices for several days. Counsel’s offices also have been
closed during this time.
4.

Pursuant to LCvR 7(m), Defendants’ counsel conferred with Plaintiff’s counsel

on this motion, and Defendants hereby file this motion unopposed.
WHEREFORE, Defendants respectfully request the entry of an order extending the time
by which Defendants must file a reply to Plaintiff’s opposition to defendants’ motion to dismiss
to and including February 19, 2010.
Dated: February 11, 2010.
Respectfully submitted,
/s/ Robert Corn-Revere
Robert Corn-Revere (D.C. Bar No. 375415)
[e-mail]
Lisa B. Zycherman (D.C. Bar No. 495277)
[e-mail]
DAVIS WRIGHT TREMAINE, LLP
1919 Pennsylvania Avenue, N.W., Suite 200
Washington, D.C. 20006
[phone]
[phone] fax
Bruce E. H. Johnson (admitted pro hac vice)
[e-mail]
Ambika Doran (admitted pro hac vice)
[e-mail]
DAVIS WRIGHT TREMAINE, LLP
1201 Third Avenue, Suite 2200
Seattle, WA 98101-3045
[phone]
[phone] fax
Thomas R. Burke (admitted pro hac vice)
[e-mail]
DAVIS WRIGHT TREMAINE, LLP
505 Montgomery Street, Suite 800
San Francisco, CA 94111-6533
[phone]
[phone] fax
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Matthew Zimmerman (pro hac vice pending)
[e-mail]
Corynne McSherry (pro hac vice pending)
[e-mail]
ELECTRONIC FRONTIER FOUNDATION
454 Shotwell Street
San Francisco, CA 94110
[phone]
[phone] fax

CERTIFICATE OF SERVICE
Pursuant to LCvR 5.3, I hereby certify that, on February 11, 2010, I electronically filed
with the Clerk of the Court the foregoing Unopposed Motion to Extend Time to File Reply Brief
and proposed order using the CM/ECF system, and service was effected electronically pursuant
to LCvR 5.4(d) on the parties listed below.

Michael John Mueller
Hunton & Williams LLP
1900 K Street, NW, Suite 1200
Washington, DC 20006
[e-mail]
Deepak Gupta
Public Citizen Litigation Group
1600 20th Street, NW
Washington, DC 20009
[e-mail]
Gregory A. Beck
Public Citizen Litigation Group
1600 20th Street, NW
Washington, DC 20009
[e-mail]
/s/ Robert Corn-Revere
Robert Corn-Revere (D.C. Bar No. 375415)

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