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Pursuant to Rule 6(b) of the Federal Rules of Civil Procedure, plaintiff’s respectfully move this
Court for an enlargement of time, up to and including November 30, 2009, in which to respond
to Defendants’ allegation of qualified immunity as ordered by the court on October 26, 2009.
Plaintiff has been diligently attempting to answer Defendant’s allegations but, due to the number
of Defendant’s allegations regarding immunity, the plaintiff has been unable to complete the
Consequently, this motion for enlargement of time is necessary in order for plaintiff’s counsel to
finish plaintiff’s brief. Plaintiffs regret the need to seek this extension of time and anticipate that
Plaintiffs did not inform defense counsel prior to submitting this motion as the motion was filed
over the weekend. On Monday, November 16, 2009, Plaintiff will attempt to contact counsel for
the Defendants and inquire regarding their position on the motion. If successful, Plaintiffs will
Respectfully submitted,
ALEXANDER B. CHING,
TEXAS BAR #00796350
Attorney for the Plaintiffs