Case 1:05-cv-01483-JDB        Document 35         Filed 09/13/2007      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 SECOND 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 additional extension of time to October 5, 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 September 21, 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.

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

been given. Additionally, coordination has been effected to establish a recommended

Defendants’ Reply Brief date of October 26, 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.


  Case 1:05-cv-01483-JDB          Document 35        Filed 09/13/2007      Page 2 of 2


                                             Respectfully submitted,


                                                 /s/ Michael W. Beasley
                                             Michael W. Beasley, Esq.
                                             200 Park Avenue, Suite 106
                                             Falls Church, Virginia 22046
                                             Phone: (703) 533-5875
                                             Fax: (703) 533-5876
                                             E-Mail: beasleys2@verizon.net
                                             Attorney for Plaintiff Marialice B. Williams

September 13, 2007


                              CERTIFICATE OF SERVICE

        I hereby certify that one copy of the foregoing “Plaintiff’s Second 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 13th day of September,

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


                                            2