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Motion For Enlargement

The plaintiff is requesting a two week extension until November 30, 2009 to respond to the defendant's allegations of qualified immunity. The court had previously ordered the plaintiff to respond by a certain date in October. However, due to the number of allegations made by the defendant regarding immunity, the plaintiff has been unable to complete their reply in the specified time. The plaintiff regrets the need to request an extension, but needs additional time for their counsel to finish the brief responding to the defendant.

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332 views2 pages

Motion For Enlargement

The plaintiff is requesting a two week extension until November 30, 2009 to respond to the defendant's allegations of qualified immunity. The court had previously ordered the plaintiff to respond by a certain date in October. However, due to the number of allegations made by the defendant regarding immunity, the plaintiff has been unable to complete their reply in the specified time. The plaintiff regrets the need to request an extension, but needs additional time for their counsel to finish the brief responding to the defendant.

Uploaded by

Steven Jones
Copyright
© Attribution Non-Commercial (BY-NC)
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOC, PDF, TXT or read online on Scribd
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IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF TEXAS


LUBBOCK DIVISION

ROBERT TEAGUE, as Personal )


Representative of the Estate of Beckie Teague )
and on Behalf of Nicole Jones, Sarah Jones, )
and Barbara Teague, )
)
Plaintiffs, )
)
v. )
GAINES COUNTY, TEXAS, et al., ) Civil Action No. 5:09-CV-231-C
)
Defendants. ) ECF

MOTION FOR ENLARGEMENT OF TIME

Pursuant to Rule 6(b) of the Federal Rules of Civil Procedure, plaintiff’s respectfully move this

Court for an enlargement of time, up to and including November 30, 2009, in which to respond

to Defendants’ allegation of qualified immunity as ordered by the court on October 26, 2009.

Plaintiff has been diligently attempting to answer Defendant’s allegations but, due to the number

of Defendant’s allegations regarding immunity, the plaintiff has been unable to complete the

reply in the specified time.

Consequently, this motion for enlargement of time is necessary in order for plaintiff’s counsel to

finish plaintiff’s brief. Plaintiffs regret the need to seek this extension of time and anticipate that

no further extension will be necessary.

Plaintiffs did not inform defense counsel prior to submitting this motion as the motion was filed

over the weekend. On Monday, November 16, 2009, Plaintiff will attempt to contact counsel for

the Defendants and inquire regarding their position on the motion. If successful, Plaintiffs will

file an amended motion.


Accordingly, for the foregoing reasons, Plaintiffs request a two (2) week extension of time to

respond to Defendants’ allegations regarding qualified immunity.

Respectfully submitted,

_/s/ Alexander Bryan Ching__________

ALEXANDER B. CHING,
TEXAS BAR #00796350
Attorney for the Plaintiffs

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