Hall et al v. Welborn et al

Filing 13

Unopposed MOTION for Extension of Time to File Response as to 8 MOTION to Dismiss by Plaintiffs Jeremy Hall, Military Religious Freedom Foundation. (Eye, Robert)

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IRIGONEGARAY & 1535 S.W. 29th Topeka, Kansas (785) 267-6115 (785) 267-9458 ASSOCIATES Street 66611-1901 FAX IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF KANSAS ) ) ) ) Plaintiffs, ) ) vs. ) ) MAJOR FREDDY J. WELBORN, and ) UNITED STATES DEPARTMENT OF DEFENSE) SECRETARY ROBERT GATES, ) ) Defendants. ) ) SPECIALIST JEREMY HALL, and MILITARY RELIGIOUS FREEDOM FOUNDATION, Case No. 08-2098 PLAINTIFFS' UNOPPOSED MOTION FOR ADDITIONAL TIME TO RESPOND TO DEFENDANTS' MOTION TO DISMISS Plaintiffs hereby moves this Honorable Court for an Order allowing them an additional thirty (30) days to respond to Defendant's Motion to Dismiss. following is stated: 1. The plaintiffs' response to the Defendants' Motion to In support of this motion, the Dismiss is currently due September 15, 2008. 2. Additional time is required due to the extensive number of issued raised by defendants and the significant documentary evidence offered in support thereof. 3. Counsel for defendants has been consulted and does not oppose this motion. WHEREFORE, plaintiffs respectfully seek additional time until October 15, 2008, to respond to Defendants' Motion to Dismiss. Respectfully submitted, IRIGONEGARAY & ASSOCIATES 1535 S.W. 29th Street Topeka, Kansas 66611-1901 (785) 267-6115 By: /s/Robert V. Eye, #10689 Attorney for Plaintiffs CERTIFICATE OF SERVICE I hereby certify that on September 12, 2008, I electronically filed Plaintiffs' Unopposed Motion for Additional Time to Respond to Defendants' Motion to Dismiss with the clerk of the court by using the CM/ECF system which will send a notice of electronic filing to the following: eric.beckenhauer@usdoj.gov, pli@plilaw.com, bob@plilaw.com, erh@irigonegaray.com, and myrna@plilaw.com. I further certify that I mailed the aforesaid document and notice of electronic filing by first class mail to the following non-CM/ECF participants: No one. /s/Robert V. Eye, #10689 -2-

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