Case 1:05-cv-01483-JDB        Document 36         Filed 10/04/2007      Page 1 of 2


                         UNITED STATES DISTRICT COURT
                         FOR THE DISTRICT OF COLUMBIA


                                                      )
MARIALICE BATHRUS WILLIAMS,                           )
                                                      )
                Plaintiff,                            )
                                                      )
v.                                                    ) Civil Action No. 05-cv-1483
                                                      )             (JDB)
FANNIE MAE, et al.,                                   )
                                                      )
                Defendants.                           )
                                                      )

                  PLAINTIFF’S UNOPPOSED MOTION FOR
                 EXTENSION OF TIME TO FILE OPPOSITION
            TO DEFENDANTS’ MOTION FOR SUMMARY JUDGMENT

         Plaintiff Marialice Bathrus Williams, by and through counsel, hereby moves for

an additional extension of time to October 12, 2007, for filing her Opposition to the

Defendants’ Motion for Summary Judgment in this proceeding. The current deadline for

the filing of such Opposition is October 5, 2007.

         The purpose of the requested extension of time is to permit the parties to

conclude, execute and file settlement documents pursuant to Rule 41 of the Federal Rules

of Civil Procedure. While it originally was anticipated that such actions would be

complete by October 5, 2007, the parties are still reaching agreement on specific terms

and language of the settlement agreement.

         This motion has been discussed with counsel for the Defendants, and Defendants

do not oppose this further motion for additional time. Additionally, coordination has

been accomplished to establish a recommended Defendants’ Reply Brief date of


  Case 1:05-cv-01483-JDB          Document 36       Filed 10/04/2007      Page 2 of 2


November 2, 2007, preserving the 21-day period in which Defendants may reply to any

Opposition filed.

       A proposed Order is provided herewith for the Court’s consideration.

                                            Respectfully submitted,

                                                /s/ Michael W. Beasley
                                            Michael W. Beasley, Esq.
                                            200 Park Avenue, Suite 106
                                            Falls Church, Virginia 22046
                                            Phone: (703) 533-5875
                                            E-Mail: beasleys2@verizon.net
                                            Attorney for Plaintiff Marialice B. Williams

October 4, 2007


                            CERTIFICATE OF SERVICE

       I hereby certify that one copy of the foregoing “Plaintiff’s Unopposed Motion for

Extension of Time to Respond to Defendants’ Motion for Summary Judgment,” with

proposed Order, has been served through the Court’s ECF filing system to each of the

following named counsel for Defendants, this 4th day of October, 2007:

Sarah Alexander Goldfrank, Esq.
Evelyn L. Becker, Esq.
Kyra Anne Grundeman, Esq.
O’Melveny & Myers, LLP
1625 I Street, N. W.
Washington, D. C. 20006

Jonathan Lee Griffith, Esq.
Fannie Mae
3900 Wisconsin Avenue, N. W.
Washington, D. C. 20016


                                               /s/ Michael W. Beasley
                                            Michael W. Beasley, Esq.
                                            D. C. Bar No. 248930
                                            Attorney for Plaintiff


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