Lu v. Hulme et al

Filing 24

MOTION for Extension of Time to June 27, 2013 to File Answer by George Hulme, Trustees of Boston Public Library. (Attachments: # 1 Memorandum of Law in Support of Motion for Leave to File Late Answers, # 2 Exhibit A, # 3 Exhibit B)(Driscoll, Caroline)

UNITED STATES DISTRICT COURT
DISTRICT OF MASSACHUSETTS
CIVIL ACTION NO. 12-11117-MLW

FRIEDRICH LU,
Plaintiff,
v.
GEORGE HULME, in his individual
capacity and in his official capacity,
TRUSTEES OF THE BOSTON PUBLIC
LIBRARY,
Defendants.

DEFENDANTS GEORGE HULME AND THE TRUSTEES OF THE BOSTON PUBLIC
LIBRARY’S MOTION FOR LEAVE TO FILE LATE ANSWERS

Now come the Defendants George Hulme (“Hulme”) and the Trustees of the Boston
Public Library (“Trustees”) (collectively, “Defendants”) hereby respectfully move this Court
pursuant to Federal Rule 6(b)(1)(B) to accept late filing of their Answers.
As grounds for this Motion, Defendants state that their respective Answers are late due to
excusable neglect, based on counsel’s misinterpretation of this Court’s Order and Memorandum
regarding Defendants’ Motion to Dismiss, and that this delay has not caused any prejudice or
harm to the Plaintiff.
Further grounds of support are set forth in the accompanying memorandum of law.

Respectfully submitted,
DEFENDANTS GEORGE HULME, in his
individual capacity and in his official capacity
and TRUSTEES OF THE BOSTON PUBLIC
LIBRARY
William Sinnott
Corporation Counsel
By their attorneys:

Date: June 27, 2013

/s/Caroline O. Driscoll_________
Caroline O. Driscoll, BBO# 647916
Assistant Corporation Counsel
City of Boston Law Department
City Hall, Room 615
Boston, MA 02201
[phone]
[e-mail]

LOCAL RULE 7.1 CERTIFICATION
I certify that on June 26, 2013, I attempted to contact Plaintiff via email to consult with
him regarding the relief sought in this motion. As of the time of filing, Plaintiff has not
responded to my email. I also certify that on June 27, 2013, I filed this document through the
Court’s CM/ECF system and that an electronic copy will be sent via email to those identified as
non-registered participants per agreement with Plaintiff.

/s/Caroline O. Driscoll
Caroline O. Driscoll

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