KUCINICH et al v. OBAMA et al

Filing 9

Unopposed MOTION for Extension of Time to File Response/Reply as to 8 MOTION to Dismiss by ROSCOE BARTLETT, DAN BURTON, MICHAEL E. CAPUANO, HOWARD COBLE, JOHN CONYERS, JR, JOHN J. DUNCAN, JR, TIMOTHY V. JOHNSON, WALTER B. JONES, DENNIS KUCINICH, RON PAUL (Attachments: # 1 Text of Proposed Order)(Turley, Jonathan)

IN THE UNITED STATES DISTRICT COURT 
FOR THE DISTRICT OF COLUMBIA 

DENNIS KUCINICH, et al., 
)  

)
Plaintiffs,
)
Case No. 1:11-cv-01096 (RBW)

) 

v. 
) 

) 
BARACK OBAMA, et al., 
) 

) 

Defendants. 
) 

_________________________________________________________) 

PLAINTIFFS’ UNOPPOSED (FIRST) MOTION FOR AN EXTENSION OF TIME
Pursuant to Federal Rule of Civil Procedure 6(b), Plaintiffs request a 7-day extension
of time, until September 9, 2011, within which to file their opposition to the Motion to
Dismiss filed by the Defendants. This request is made in good faith and with good cause,
as set forth below.
1.

The original date for the filing of the opposition memorandum was September
2, 2011.

2.

Plaintiffs’ counsel, however, must confer with members of Congress before
filing this opposition. Most members are currently out of town. Plaintiffs’
counsel also returned recently from weeks out of the country and has been
addressing previously scheduled filings and hearings in other federal cases.

3.

Defendants have filed an extensive memorandum challenging the basis for the
Complaint, which covers a broad scope of jurisdictional and policy arguments.

4.

This is the first motion for an extension requested by the Plaintiffs.

5.

The Defendants consent to the seven (7) day enlargement of time to allow

Plaintiffs to file their Opposition.
Dated: August 29, 2011
Respectfully submitted,

/s/ Jonathan Turley
______________________________        
JONATHAN TURLEY (D.C. Bar 417674)
2000 H St., N.W.
Washington, D.C. 20052
[phone]
Counsel for the Plaintiffs

CERTIFICATE OF SERVICE
Pursuant to LCvR 5.3, I hereby certify that, on August 29, 2011, I electronically
filed with the Clerk of the Court the foregoing Proof of Service of UNOPPOSED
MOTION FOR EXTENSION OF TIME TO OPPOSE THE DEFENDANTS’ MOTION
TO DISMISS using the CM/ECF system, and service was effected electronically
pursuant to LCvR 5.4(d) on the following party:

ERIC R. WOMACK, IL Bar No. 6279517
Trial Attorney
United States Department of Justice Civil Division,
Federal Programs Branch
20 Massachusetts Ave., NW
Washington, DC 20001
Tel: [phone] Fax: [phone]
/s/ Jonathan Turley
________________________________
JONATHAN TURLEY(D.C. Bar No. 417674) 
2000 H Street, N.W.
Washington, DC 20052
[phone]
Counsel for the Plaintiffs