Hagen Motion for Extension of Time to Reply
5
IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WASHINGTON RYDER, CHRIS : CASE NO: 10-cv-1002 : JUDGE MJP Plaintiff : : : v. : July 17, 2010 HAGEN, KATRINA, M. Defendant Motion for Extension of Time to Reply to Defendant’s Motion to Dismiss Facts: Plaintiff filed the above captioned action against the defendant in this Court. The defendant entered an appearance with local counsel from the State of Washington. The Court granted a Motion to Leave and the attendant application for an appearance by counsel Pro Hac Vice. The Motion and application were granted by the office of the Chief Clerk of the Court. The defendant has presented the plaintiff with an elaborately prepared Motion to Dismiss, along with a memorandum. Plaintiff requires an additional three weeks to sufficiently
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Motion for Extension of Time To File Reply to Defendant's Motion to Dismiss
Transcript of Hagen Motion for Extension of Time to Reply
IN THE UNITED STATES DISTRICT COURTFOR THE WESTERN DISTRICT OF
WASHINGTON
RYDER, CHRIS: CASE NO: 10-cv-1002: JUDGE MJP
Plaintiff :::
v. : July 17, 2010
HAGEN, KATRINA, M.
Defendant
Motion for Extension of Time to Reply to Defendant’s Motion to Dismiss
Facts: Plaintiff filed the above captioned action against the defendant in this Court.
The defendant entered an appearance with local counsel from the State of Washington.
The Court granted a Motion to Leave and the attendant application for an appearance by
counsel Pro Hac Vice. The Motion and application were granted by the office of the Chief
Clerk of the Court.
The defendant has presented the plaintiff with an elaborately prepared Motion to
Dismiss, along with a memorandum. Plaintiff requires an additional three weeks to
sufficiently respond to the defendant’s Motion. It is also the Plaintiff’s intention to implede
Harvard University into this case through a Motion for Joinder. Harvard University has
already entered an appearance for the defendant through the office of its General Counsel.
Secondly, the Plaintiff is trying to complete a brief for the Supreme Court which is
due in early September and this matter predates the filing of the instant case by a long
measure. Third, Harvard University has inexplicably ‘cut off’1 the plaintiff from using the
Lexis data base that the plaintiff would ordinarily be entitled to utilize, thus blunting his
ability to conduct adequate research to rebuff the claims and legal posture presented in the
defendant’s Motion to Dismiss.
Plaintiff hereby requests an extension of 21 days to reply. A copy of the proposed
order is attached.
Respectfully submitted,s/ Chris Ryder
CHRIS RYDER1 And no one at Harvard can explain logically why this has occurred.
Pro SeP O Box 380949Cambridge, Mass 02138Telephone: 202. 489-9292Fax: 202-380-9121Email: [email protected]
IN THE UNITED STATES DISTRICT COURTFOR THE WESTERN DISTRICT OF
WASHINGTON
RYDER, CHRIS: CASE NO: 10-cv-1002: JUDGE MJP
Plaintiff :::
v. : July 17, 2010
HAGEN, KATRINA, M.
DefendantORDER
The Plaintiff’s Motion for an Extension of Time to File a Reply to Defendant’s Motion to
Dismiss is hereby granted/denied.
Date________________
__________________________
Hon. Marsha J. Pechman, UDCJ
