WILLIAMS v. FANNIE MAE — Entry #34: Consent MOTION for Extension of Time to File Response/Reply as to [33] MOTION for Summary Judgment by MARIALICE BATHRUS WILLIAMS

Case 1:05-cv-01483-JDB        Document 34         Filed 07/09/2007      Page 1 of 3


                         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 CONSENT 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 extension of time to Friday, September 21, 2007, for filing her Opposition to the

Defendants’ Motion for Summary Judgment in this proceeding. This motion has been

discussed with counsel for the Defendants, and consent therefore has been given.

         In support hereof, the following information is provided:

         1. Defendants filed their Motion for Summary Judgment with the Court on June

21, 2007. The deadline for the filing of Plaintiff’s Opposition currently is established as

no later than July 23, 2007, as set by the Court’s Minute Order entered December 15,

2006.

         2. Plaintiff and Plaintiff’s counsel have been substantially and materially delayed

in preparing the Opposition because of the sudden death of case co-counsel Harley J.

Daniels, Esq., on June 26, 2007. Prior to his death, Mr. Daniels had assumed the primary


  Case 1:05-cv-01483-JDB           Document 34         Filed 07/09/2007        Page 2 of 3


counsel role for Plaintiff, and he has been critically involved in all phases of this

proceeding.

       3. Moreover, the two remaining counsel for Plaintiff in this case are significantly

involved in Mr. Daniels’ Estate, which includes provision of care and guardianship of a

minor child, and a number of other complicating issues. Mr. Beasley is the named

Personal Representative of the Estate, and Mr. Lederer is the attorney for the Estate. Mr.

Beasley and Mr. Lederer also are each involved in several other ongoing Federal and

State Court proceedings.

       4. For all of these reasons, Plaintiff and counsel will require a period of

approximately two additional months to complete the Opposition filing.

       5. The original schedule for the filing of Defendants’ Reply was set for three

weeks following the filing of Plaintiff’s Opposition (pursuant to the Court’s Minute

Order of December 15, 2006). If this period is maintained following the proposed

revised date for the filing of Plaintiff’s Opposition (i.e. September 21, 2007), the Reply

would be due not later than October 12, 2007. The parties propose that this be the

revised date for the reply submission, should this motion be granted.

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

                                               Respectfully submitted,

                                                   /s/ Michael W. Beasley
                                               Michael W. Beasley, Esq.
                                               D. C. Bar No. 248930
                                               200 Park Avenue, Suite 106
                                               Falls Church, Virginia 22046
                                               Phone: (703) 533-5875
                                               E-Mail: beasleys2@verizon.net

                                               Attorney for Plaintiff Marialice B. Williams
Attachment 1: Proposed Order


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  Case 1:05-cv-01483-JDB          Document 34       Filed 07/09/2007       Page 3 of 3


                             CERTIFICATE OF SERVICE

       I hereby certify that one copy of the foregoing “Plaintiff’s Consent 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 9th day of July, 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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