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

Filing 48

Unopposed MOTION for Extension of Time to File Motion for Summary Judgment by ALLIANCE FOR JUSTICE, NATIONAL CONSUMER LAW CENTER, NATIONAL VETERANS LEGAL SERVICES PROGRAM (Attachments: #1 Text of Proposed Order)(Gupta, Deepak)

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
NATIONAL VETERANS LEGAL
SERVICES PROGRAM, NATIONAL
CONSUMER LAW CENTER, and
ALLIANCE FOR JUSTICE, for themselves
and all others similarly situated,
Plaintiffs,

Case No. 16-745-ESH

v.
UNITED STATES OF AMERICA,
Defendant.
PLAINTIFFS’ UNOPPOSED MOTION TO EXTEND BRIEFING SCHEDULE
AND SUPPORTING MEMORANDUM
The plaintiffs hereby request an extension of the time in which to file their motion for
summary judgment. The motion is currently due on July 27, 2017, ten days after the class-notice
period ends. The plaintiffs respectfully request an extension of 30 days, up to and including
August 28, 2017. The government consents to this request. A proposed order is attached.
The purpose of this extension is to provide the government with additional time to
respond to the plaintiffs’ requests for discovery relevant to their anticipated summary-judgment
motion—as contemplated by this Court’s scheduling order of January 24, 2017. Dkt. 34. The
plaintiffs have been seeking informal discovery from the government since late January, and
formal discovery for the past three weeks. In response to these requests, the government has
produced three documents to date—all before the plaintiffs served formal discovery on June 12.
The government anticipates producing additional documents and/or interrogatory responses,
which we had hoped to start receiving on a rolling basis last week. We now understand that we
may not receive this additional discovery until next week or even later. The government’s counsel

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has cited competing scheduling obligations and the need to coordinate with clients as the basis
for the delay. An extension should allow the government and its counsel sufficient time to meet
the pending requests.
Respectfully submitted,
/s/ Deepak Gupta
Deepak Gupta (D.C. Bar No. 495451)
GUPTA WESSLER PLLC
1900 L Street, NW
Suite 312
Washington, DC 20036
[phone]
William H. Narwold (D.C. Bar No. 502352)
MOTLEY RICE LLC
3333 K Street NW, Suite 450
Washington, DC 20007
202) 232-5504
Attorneys for Plaintiffs
July 5, 2017

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CERTIFICATE OF SERVICE
I hereby certify that on July 5, 2017, I filed this motion to extend the briefing schedule
through this Court’s CM/ECF system, which will send a notice of electronic filing to all counsel
required to be served.
/s/ Deepak Gupta
Deepak Gupta

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