Inniss et al v. Aderhold et al

Filing 44

MOTION for Extension of Time to File a Reply in Support of Defendants Pending Motion to Dismiss and Proposed Order by Deborah Aderhold, Monica P. Fenton. (Orland, Devon)

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 et al,
Defendants.

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

UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE A REPLY
IN SUPPORT OF DEFENDANTS’ PENDING MOTION TO DISMISS
COME NOW, Defendant Aderhold and Defendant Fenton (hereinafter
Defendants), by and through Samuel Olens the Attorney General for the State of
Georgia, and hereby move for an extension of time of thirty (30) days in which to
file a reply in support of their Motion to Dismiss Plaintiffs’ Amended Complaint.
Defendants’ response is currently due on September 22, 2014 and Defendants seek
an extension until October 22, 2014.
This case presents complicated issues with eight named Plaintiffs and unique
and important constitutional issues. The matter at issue in this case is being
litigated throughout the Country and the state of the law is in flux throughout the
various state and federal courts. Defendants wish to appropriately capture and
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address the rapidly evolving legal developments within their briefing while
adequately responding to the issues addressed in Plaintiffs’ response. 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.
Respectfully submitted,
SAMUEL S. OLENS
Attorney General

551540

KATHLEEN M. PACIOUS
Deputy Attorney General

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Nels Peterson
Solicitor General

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/s/ Devon Orland
554301
Senior Asst. Attorney General
Counsel for Defendant Aderhold and Fenton

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CERTIFICATE OF SERVICE

I hereby certify that on this date I have electronically filed the foregoing
UNOPPOSED 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 11th day of September, 2014.
/s/ Devon Orland
40 Capitol Square, S.W.
Atlanta, Georgia 30334-1300
Telephone: [phone]
Facsimile: [phone]
E-mail: [e-mail]

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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, et al.
Defendants.

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

ORDER
THIS MATTER coming before the Court on Defendants’ Unopposed
Motion for Extension of Time to file a Reply in support of their Motion to
Dismiss, due notice to the parties and the Court being advised of the premises and
good cause shown, IT IS HEREBY ORDERED THAT:
Defendants’ Motion is GRANTED. Defendants shall have an additional
thirty (30) days, up to and including October 22, 2014, in which to respond to
Plaintiffs’ Complaint.

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IT IS SO ORDERED, this ____ day of _______________, 2014.

____________________________
Hon. William S. Duffey Jr.
United States District Judge

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