Tobey v. Napolitano et al

Filing 4

MOTION for Extension of Time to File Answer and Other Responsive Pleadings by Capital Region Airport Commission, Calvin Vann, Victor Williams. (Attachments: # 1 Exhibit A- Sketch Order)(Jones, Belinda)

Tobey v. Napolitano et al

Doc. 4

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division AARON TOBEY, Plaintiff, v. JANET NAPOLITANO, et al. Defendants. ) ) ) ) ) ) ) ) )

Civil Action No. 3:11cv154-HEH

DEFENDANTS CAPITAL REGION AIRPORT COMMISSION, VICTOR WILLIAMS, AND CALVIN VANN'S, UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE RESPONSIVE PLEADINGS Defendants, Capital Region Airport Commission ("CRAC"), Victor Williams ("Williams"), and Calvin Vann ("Vann"), by counsel, and pursuant to Local Civil Rule 7(F)(2) of the Eastern District of Virginia, respectfully file this motion for an extension of time to file their responsive pleadings to the Complaint. In support of this motion CRAC, Williams, and Vann state as follows: 1. 2011. 2. CRAC was served with the Complaint and Summons on or about March 16, 2011, Aaron Tobey ("Tobey") filed his Complaint in this action on or about March 10,

making its responsive pleadings thereto due on or about April 6, 2011. 3. Williams was served with the Complaint and Summons on or about March 15,

2011, making his responsive pleadings thereto due on or about April 5, 2011. 4. Vann was served with the Complaint and Summons on or about March 15, 2011,

making his responsive pleadings thereto due on or about April 5, 2011.

Dockets.Justia.com

5.

Upon information and belief, those other Defendants that are affiliated with the

federal government have their responsive pleadings due on or about May 15, 2011. 6. CRAC, Williams and Vann seek an extension up to and including May 15, 2011,

to prepare and file their responsive pleadings simultaneously with the other Defendants. 7. 8. Counsel for Tobey has confirmed that they do not oppose this motion. A Consent Order providing for this extension is attached as Exhibit A. The parties

will file an endorsed copy of the Consent Order with the Court. WHEREFORE, for the foregoing reasons, CRAC, Williams and Vann respectfully request that the Court grant their motion and grant them an extension of time to up to and including May 15, 2011, to file their responsive pleadings. Respectfully submitted, CAPITAL REGION AIRPORT COMMISSION, VICTOR WILLIAMS, and CALVIN VANN By Counsel /s/Belinda D. Jones Paul W. Jacobs II (VSB No. 16815) Henry I. Willett, III (VSB No. 44655) Belinda D. Jones (VSB No. 72169) CHRISTIAN & BARTON, L.L.P. 909 East Main Street, Suite 1200 Richmond, Virginia 23219-3095 Tel: [phone] Fax: [phone] Email: [e-mail] Email: [e-mail] Email: [e-mail] Counsel for Defendants Capital Region Airport Commission, Victor Williams and Calvin Vann

2

CERTIFICATE OF SERVICE I hereby certify that on the 30th day of March, 2011, the foregoing was electronically filed with the Clerk of Court using the CM/ECF system which will send notification of such filing to all counsel of record, including: James Jeffrey Knicely KNICELY & ASSOCIATES 487 McLaws Circle PO Box GK Williamsburg, VA 23187 Tel: [phone] Email: [e-mail] Counsel for Aaron Tobey

/s/Belinda D. Jones______ Belinda D. Jones (VSB No. 72169) CHRISTIAN & BARTON, L.L.P. 909 East Main Street, Suite 1200 Richmond, Virginia 23219-3095 Tel: [phone] Fax: [phone] Email: [e-mail]

1140146

3