| IN THE UNITED STATES DISTRICT COURT|
FOR THE DISTRICT OF COLUMBIA
UNITED STATES OF AMERICA,
SMITHFIELD FOODS, INC.,
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| Civil Action No.1:03-CV-00434 (HHK) |
PLAINTIFF'S STATEMENT OF POINTS AND AUTHORITIES IN SUPPORT OF ITS UNCONTESTED MOTION FOR ENTRY OF ORDER FOR EXTENSION OF TIME FOR PLAINTIFF TO FILE ITS REPLY MEMORANDUM IN RESPONSE TO DEFENDANT'S MEMORANDUM OF POINTS AND AUTHORITIES IN OPPOSITION TO PLAINTIFF'S MOTION TO COMPEL AND FOR AN EXTENSION OF TIME FOR JURISDICTIONAL DISCOVERY
In support of its Motion for an Extension of Time, Plaintiff relies upon the following:
- Plaintiff's Motion is authorized by Rule 7(b) of the Fed. R. Civ. P., as well as Rule 7.1 of the LcvR.
- The time for filing a Reply Memorandum by Plaintiff, if necessary, may expire before the Court rules on the Defendant's Motion to Vacate. Without knowing how the Court may rule of the Defendant's outstanding Motion to Vacate this Court's Order granting the Plaintiff's Motion to Compel, or whether any order to vacate may include a time for the filing of any Reply Memorandum, Plaintiff wants to preserve its right to file a Reply Memorandum as authorized by Rule 7.1(d) of the LcvR. Plaintiff believes that the only way to insure that its rights to file such a Reply Memorandum will be preserved, is to request the entry of an order setting a date certain by which such Reply should be filed.
Wherefore, Plaintiff respectfully requests the entry of the attached Order granting the Plaintiff an extension of time to July 25, 2003, for the filing of its Reply Memorandum in response to the Defendant's Memorandum of Points and Authorities in Opposition to the Plaintiff's Motion to Compel Compliance with Plaintiff's Discovery Requests and for an Extension of Time for Jurisdictional Discovery.
Dated this 24th day of July, 2003.
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| ||Respectfully submitted, |
Plaintiff, United States
Nina B. Hale
Jessica K. Delbaum
Alexander Hewes, Jr.
D.C. Bar No. 150284
United States Department of Justice
325 Seventh Street, NW, Suite 500
Washington, D.C. 20530