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

Filing 80

Consent MOTION to Continue Motions Hearing by UNITED STATES OF AMERICA (Field, Brian)

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

Civil Action No. 16-745 (ESH)

UNITED STATES OF AMERICA
Defendant.
DEFENDANT’S CONSENT MOTION TO CONTINUE MOTIONS HEARING
Pursuant to Federal Rule of Civil Procedure 6(b), Defendant, by and through the
undersigned counsel, respectfully moves this Court to continue the Motions Hearing currently
scheduled for March 19, 2018 at 11:00 a.m. See Min. Order (Feb. 27, 2018). In accordance with
Local Civil Rule 7(m), the undersigned has conferred with Plaintiffs’ counsel, who stated that
Plaintiffs consent to the relief requested in this Motion.
There is good cause to grant the relief requested in this Motion:
1.

The Parties completed briefing their cross-motions for summary judgment on

January 5, 2018. On February 27, 2018, this Court scheduled a Motions Hearing for March 19,
2018, at 11:00 a.m. See Min. Order (Feb. 27, 2018).
2.

Unfortunately, this Motions Hearing conflicts with long-scheduled international

travel on the part of AUSA Field, who will be presenting arguments on Defendant’s behalf.1

1

Specifically, AUSA Field will have just returned from an extended international trip late in the
evening of March 17 and the current schedule will significantly hinder his ability to prepare.

3.

The Parties have conferred and are available to participate in the Motions Hearing

on any of the following dates: April 19, May 2–3, 10–11, 14, 17, 21–25.2
4.

Accordingly, Defendant respectfully requests that the Court continue the Motions

Hearing to a later date when the undersigned will be available to attend. There are no other pending
deadlines or court dates that this request for a continuance would affect.
March 1, 2018

Respectfully submitted,
JESSIE K. LIU
D.C. BAR #472845
United States Attorney
DANIEL F. VAN HORN
D.C. BAR #924092
Chief, Civil Division
By:

2

/s/ Brian J. Field
BRIAN J. FIELD
D.C. BAR #985577
Assistant United States Attorney
555 4th Street, N.W.
Washington, D.C. 20530
Tel: [phone]
E-mail: [e-mail]

These dates take into account several additional scheduling conflicts, including an upcoming jury
trial, medical procedure, travel, and depositions that cannot be rescheduled without substantial
prejudice to witnesses.