NATIONAL VETERANS LEGAL SERVICES PROGRAM et al v. UNITED STATES OF AMERICA

Filing 16

Unopposed MOTION for Extension of Time to File Response/Reply as to #11 MOTION to Dismiss Or, In The Alternative MOTION for Summary Judgment by UNITED STATES OF AMERICA (Attachments: #1 Text of Proposed Order)(Nebeker, William)

Case 1:16-cv-00745-ESH Document 16 Filed 08/04/16 Page 1 of 3

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
NATIONAL VETERANS LEGAL
SERVICES PROGRAM, et al.,

)
)
)
Plaintiffs,
)
)
v.
) Civil Action No. 16-745 ESH
)
UNITED STATES OF AMERICA,
)
)
Defendant.
)
)
______________________________)
UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME,
AND MEMORANDUM IN SUPPORT THEREOF
Defendant hereby moves, pursuant to Fed. R. Civ. P. 6(b)(1), for
an enlargement of time of six business days to reply to Plaintiffs’
opposition to the pending Motion To Dismiss Or, In The Alternative,
For Summary Judgment.
2016.

This would make the response due on August 16,

Counsel for Plaintiffs, William H. Narwold, Esq., has agreed

to the requested enlargement of time.
Defendant seeks this additional time because his
responsibilities in several other matters have made it impossible to
complete the needed reply by the current due date of August 8, 2016.
Counsel has been working to complete a lengthy dispositive motion in
another case involving individual capacity claims against federal
employees of two federal agencies.

At the same time, he has been

preparing two other dispositive motions (one of which involves

Case 1:16-cv-00745-ESH Document 16 Filed 08/04/16 Page 2 of 3

classified information), both of which are also due on the date that
the reply is currently due in this action, Monday, August 8, 2016.
For these reasons, Defendant asks for an enlargement of time
to file a reply in the case up to and including August 16, 2016.
proposed order accompanies this motion.
Respectfully submitted,

CHANNING D. PHILLIPS, DC Bar #415793
United States Attorney

DANIEL F. VAN HORN, DC Bar #924092
Chief, Civil Division

By:

/s/
W. MARK NEBEKER, DC Bar #396739
Assistant United States Attorney

-2-

A

Case 1:16-cv-00745-ESH Document 16 Filed 08/04/16 Page 3 of 3

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that service of the foregoing Unopposed Motion
For An Enlargement Of Time, And Memorandum In Support Thereof, and
a proposed Order has been made through the Court’s electronic
transmission facilities on this 4th day of August, 2016.

/s/
W. MARK NEBEKER, DC Bar #396739
Assistant United States Attorney
555 4th Street, N.W.
Washington, DC 20530
[phone]
[e-mail]