Massachusetts Bay Transportation Authority v. Anderson et al

Filing 46

MOTION for Extension of Time to 8/18/2008 8:00 PM to File Motion for Preliminary Injunction by Massachusetts Bay Transportation Authority.(Mahony, Ieuan-Gael)

UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS MASSACHUSETTS BAY TRANSPORTATION AUTHORITY Plaintiff v. Civil Action No. 08-11364-GAO ZACK ANDERSON, RJ RYAN, ALESSANDRO CHIESA, RONALD L. RIVEST, and the MASSACHUSETTS INSTITUTE OF TECHNOLOGY Defendants MOTION FOR THREE HOUR EXTENSION OF TIME

Pursuant to Fed. R. Civ. P. 6(b), Plaintiff, Massachusetts Bay Transportation Authority (the "MBTA"), moves to enlarge the time for it to file its Motion for Entry of Preliminary Injunction, supporting Memorandum, Supplemental Declarations and other supporting materials. The current deadline is Monday, August 18, 2008 at 5:00 PM EST and Plaintiff requests an extension until Monday, August 18, 2008 at 8:00 PM EST. As grounds for this motion, Plaintiff states as follows: 1. Given the nature and complexity of the underlying action, the MBTA required

additional time to collect materials in support of its Motion for Entry of Preliminary Injunction. The MBTA wishes to provide this Court with a sufficient record for making a decision concerning the Motion for Entry of a Preliminary injunction; 2. Counsel for MIT Students produced documents Saturday night that required

careful study, thereby requiring additional time; and

1

3.

Counsel for MIT consents to Plaintiff's Motion for Three Hour Extension of

Time, but counsel for the MIT Students does not consent.

MASSACHUSETTS BAY TRANSPORTATION AUTHORITY By its attorneys, _/s/ Ieuan G. Mahony _________________ Ieuan G. Mahony (BBO #552349) Maximillian J. Bodoin (BBO # 667240) HOLLAND & KNIGHT LLP 10 St. James Avenue Boston, MA 02116 [phone] ______________________________________ Thomas F.S. Darling III (BBO #558848) MASSACHUSETTS BAY TRANSPORTATION AUTHORITY State Transportation Building, 7th Floor 10 Park Plaza Boston, MA 02116 [phone] Dated: August 18, 2008 Boston, Massachusetts

2

CERTIFICATE OF SERVICE I, Ieuan G. Mahony, Attorney for the Massachusetts Bay Transportation Authority in connection with the above-captioned proceeding, hereby certify that on this 18th day of August, 2008, the Motion for Three Hour Extension of Time was served via the ECF system on the following interested parties: Party Counsel

Zack Anderson, RJ Ryan, Emily Berger, Esquire and Alessandro Chiesa Email: [e-mail] (the "MIT Undergrads") Jennifer Granick, Esquire Email: [e-mail] John Reinstein, Esquire Email: [e-mail] Massachusetts Institute of Technology ("MIT") Jeffrey Swope, Esquire Email: [e-mail]

/s/ Ieuan G. Mahony____________________

# 5550067_v1

3