Tobey v. Napolitano et al

Filing 71

Consent MOTION for Extension of Time to File Response/Reply as to 70 Memorandum in Opposition and Memorandum in Opposition to Defendant's Motion to Dismiss by Jane Doe. (Meier, Robin). Modified docket entry on 11/07/2011. (walk, ).

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

CONSENT MOTION TO EXTEND TIME
COMES NOW Transportation Security Officer Jane Doe, by Robin P. Meier, Assistant
United States Attorney for the Eastern District of Virginia, and, pursuant to Fed. R. Civ. P. 6(b),
herewith seeks an extension of one week in which to file a Reply Memorandum in Support of
Motion to Dismiss Plaintiff’s Second Amended Complaint, from November 10, 2011 to
November 17, 2011, based upon the following:
1. Doe filed a motion to dismiss on October 21, 2011. Plaintiff’s response to the motion
was filed on November 4, 2011, and Doe’s reply is due to be filed on November 10, 2011.
2. Because of pre-existing deadlines in other cases, a one-week extension is necessary in
order for counsel for Doe to submit a complete and appropriate reply brief.
3. Plaintiff stipulates to the request for a one-week extension of time, or until November
17, 2011, for Doe to file a reply in support of the motion to dismiss.
WHEREFORE, for the reasons stated herein, Doe respectfully requests the Court to grant
a one-week extension of time, until November 17, 2011, to file a reply in support of motion to
dismiss.
Dated this 4th day of November, 2011

Respectfully submitted,
NEIL H. MACBRIDE
UNITED STATES ATTORNEY
By:

/s/
Robin P. Meier
Virginia State Bar No. 65825
Assistant United States Attorney
United States Attorney’s Office
600 East Main Street, Suite 1800
Richmond, Virginia 23219
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]

TONY WEST
Assistant Attorney General
SANDRA M. SCHRAIBMAN
Assistant Branch Director
CARLOTTA P. WELLS
Senior Trial Counsel
U.S. Department of Justice
Civil Division, Federal Programs Branch
P.O. Box 883
Washington, D.C. 20044
[phone] (telephone)
Attorneys for Federal Defendants

-2-

CERTIFICATE OF SERVICE
I hereby certify that on this 4th day of November, 2011, I electronically filed the
foregoing with the Clerk of Court using the CM/ECF system, which will send a notification of
such filing (NEF) to the following:
Alan C Veronick
Anand Agneshwar

[e-mail]
[e-mail]

Belinda Duke Jones

[e-mail]

Henry Irving Willett , III
[e-mail]

[e-mail], [e-mail],

James Jeffrey Knicely [e-mail], [e-mail],
[e-mail], [e-mail]
Paul Wilbur Jacobs , II

[e-mail]

By:

/s/
Robin P. Meier
Virginia State Bar #65825
Attorney for Defendant
Office of the United States Attorney
600 East Main Street, Suite 1800
Richmond, Virginia 23219
[phone] (phone)
[phone] (fax)
[e-mail]