Pasco v. Zimmerman et al
Filing
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Second MOTION for Extension of Time to File Response/Reply as to 12 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM, 11 Brief / Memorandum in Support, 9 Brief / Memorandum in Support, 10 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM, 8 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM, 13 Brief / Memorandum in Support by Robert L. Pasco. (Attachments: # 1 Text of Proposed Order)
IN THE UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF VIRGINIA
Roanoke Division
ROBERT L. PASCO,
Plaintiff,
v.
HANK ZIMMERMAN, et al.,
Defendants.
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Civil Action No. 5:11CV00087
CONSENT MOTION FOR EXTENSION OF TIME TO RESPOND TO
MOTIONS TO DISMISS OF DEFENDANTS ZIMMERMAN, LIBRARY AND BOARD
The plaintiff Robert L. Pasco, by counsel and pursuant to Rule 6 of the Federal Rules of
Civil Procedure and with the consent of the Defendants, through their counsel, moves the Court
for an extension of time through and including January 20, 2012 within which to respond to and
file his opposition to the Motions to Dismiss of Defendants Zimmerman, Library and Board of
Trustees, and shows the Court as follows:
1.
Plaintiff’s memorandum in opposition to the motions to dismiss of all defendants
in this case is due on January 17, 2012 pursuant to a previous consent extension granted by the
Court.
2.
The parties previously have agreed to February 7, 2012 at 1:00 p.m. as the date
and time for hearing on all of the motions to dismiss.
3.
Due to the large number of issues raised by the defendants Zimmerman, Board
and Library, as well as additional pressing scheduling issues in other cases, Plaintiff’s counsel
has requested, and the Defendants, through their counsel, have consented to, an extension of time
through and including January 20, 2012 within which Plaintiff’s responses and memoranda in
opposition to those Defendants’ motions to dismiss may be filed. Plaintiff will file his
opposition to Defendant Moore’s Motion to Dismiss today.
4.
The short additional extension requested by Plaintiff’s counsel still will provide
ample time for a reply from the Defendants Zimmerman, Library and Board well prior to, and
will not result in a delay of, the hearing on the Defendants’ motions to dismiss.
WHEREFORE, Plaintiff moves the Court to extend the time through and including
January 20, 2012 for Plaintiff to respond to and oppose the Motions to Dismiss of Defendants
Zimmerman, Library and Board.
ROBERT L. PASCO
By: s/Timothy E. Cupp
Timothy E. Cupp (VSB #23017)
Cupp & Cupp, P.C.
1951 Evelyn Byrd Avenue, Suite D
Harrisonburg, Virginia 22801
Email: cupplaw@comcast.net
(540)432-9988
(540)432-9557 (facsimile)
Counsel for Plaintiff
CERTIFICATE
I hereby certify that on the 17th day of January, 2012, the foregoing Consent Motion was
filed electronically with the Clerk through the CM/ECF system, which will cause electronic
copies to be served on the parties, by sending same to their attorneys of record as follows: Julia
B. Judkins, Esquire, Bancroft, McGavin, Horvath, & Judkins, P.C., 3920 University Drive,
Fairfax, VA 22030 and Melisa G. Michelsen, Esquire and J. Jay Litten, Esquire, Litten & Sipe,
LLP, 410 Neff Avenue, Harrisonburg, Virginia 22801-3434.
s/Timothy E. Cupp
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