Inniss et al v. Aderhold et al

Filing 19

Consent MOTION for Extension of Time Revised Consent Motion For Extension of Time to File a Response Either by Answer or Motion to Plaintiffs' Complaint by Deborah Aderhold, Brook Davidson, Pinkie Toomer. (Attachments: # 1 Text of Proposed Order)(Orland, Devon) Modified on 5/30/2014 in order to update motion type (anc).

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF GEORGIA
ATLANTA DIVISION

Christopher Inniss and Shelton
Stroman; Rayshawn Chandler and
Avery Chandler; Michael Bishop
And Johnny Shane Thomas; and
Jennifer Sisson, on behalf of
Themselves and all others similarly
situated,
Plaintiffs,
v.
Deborah Aderhold, in her official
capacity; Brook Davidson, in her
official capacity, and Judge Pinkie
Toomer in her official capacity,
Defendants.

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Civil Action Number
1:14-CV-01180-WSD

REVISED CONSENT MOTION FOR EXTENSION OF TIME TO FILE A
RESPONSE EITHER BY ANSWER OR MOTION TO PLAINTIFFS’
COMPLAINT

COME NOW, all Defendants, by and through their respective counsel, and
hereby move for an extension of time of thirty (30) days in which to file a response
to Plaintiffs’ Complaint. Defendants’ response is currently due on June 21, 2014
and Defendants seek an extension until July 21, 2014.
This case presents complicated issues with seven named Plaintiffs and
government Defendants of different governmental entities. Defendants hope to
confer in their responses to avoid duplicity in briefing and also wish to capture and

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address the rapidly evolving legal developments within their briefing. Additional
time will facilitate this effort which may otherwise prove difficult.
The undersigned has conferred with Plaintiffs’ counsel and is authorized to
state that Plaintiffs’ counsel has no objection to a thirty day (30) extension of time.
No party will be prejudiced as a result of the extension of time requested.
A proposed Order is attached for the Court’s convenience.

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Respectfully submitted,
SAMUEL S. OLENS
Attorney General

551540

KATHLEEN M. PACIOUS
Deputy Attorney General

558555

Nels Peterson
Solicitor General

101074

/s/ Devon Orland
554301
Senior Asst. Attorney General
Counsel for Defendant Aderhold
/s/Frank E. Jenkins, III
Georgia Bar Number: 390550
/s/Robert L. Walker
Georgia Bar Number: 554985
[phone] – Tel
[phone] – Fax
Email: [e-mail]
Email: [e-mail]
Counsel for Defendant Davidson
/s/Kaye W. Burwell
Georgia Bar Number: 775060
Deputy County Attorney
Office of the Fulton County Attorney
141 Pryor Street, S.W., Suite 4038
Atlanta, Georgia 30303
[e-mail]
Counsel for Judge Toomer

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CERTIFICATE OF SERVICE

I hereby certify that on this date I have electronically filed the foregoing
REVISED CONSENT MOTION FOR EXTENSION OF TIME TO
RESPOND and Draft Order using the CM/ECF system which will automatically
send electronic mail notification of such filing to counsel of record as follows:
Tara Borelli
William Custer
Jennifer Odom
Jennifer Dempsey
Luke Lantta

I hereby certify that I have mailed by United States Postal Service the
document to the following non-CM/ECF participants: NONE
Done this 30th day of May, 2014.
/s/ Devon Orland
Devon Orland
Georgia Bar No. 554301
Department of Law, State of Georgia
40 Capitol Square, S.W.
Atlanta, Georgia 30334-1300
Telephone: [phone]
Facsimile: [phone]
E-mail: [e-mail]

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