Case 1:11-cv-01179-RMC Document 2

Filed 08/03/11 Page 1 of 3

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA ) ) JOSEPH FARAH, JEROME CORSI, WORLDNETDAILY.COM, and WND BOOKS, ) ) ) Plaintiffs, ) ) vs. ) ) ESQUIRE MAGAZINE, INC., HEARST ) COMMUNICATIONS, INC. and MARK ) ) WARREN, ) ) Defendants.

Civil Action No. 1:11-cv-01179 (RMC)

CONSENT MOTION TO EXTEND TIME TO ANSWER OR RESPOND AND POINTS AND AUTHORITIES IN SUPPORT Defendants Hearst Communications, Inc. (publisher of Esquire magazine) and Mark Warren (collectively, “Esquire”), with the consent of plaintiffs Joseph Farah, Jerome Corsi, WorldNetDaily.com and WND Books (“Plaintiffs”), move this Court for an order extending the time by which Esquire must answer or otherwise respond to the Complaint in the abovecaptioned action, in addition to the time prescribed by the Federal and Local Rules, to and including September 6, 2011. Pursuant to Local Rule 7(m), counsel for Esquire certifies that Esquire has conferred with Plaintiffs’ counsel and has obtained Plaintiffs’ consent to the requested relief. In making this motion, Esquire does not waive, and instead preserves, any and all defenses which it may later raise. WHEREFORE, Esquire respectfully requests the entry of an order extending the time by which Esquire must answer or otherwise respond to the Complaint to and including September 6, 2011.

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Case 1:11-cv-01179-RMC Document 2

Filed 08/03/11 Page 2 of 3

Dated: August 3, 2011 Respectfully submitted, DAVIS WRIGHT TREMAINE LLP __Laura R. Handman_/s/_____________ Laura R. Handman (D.C. Bar No. 444386) laurahandman@dwt.com 1919 Pennsylvania Ave., N.W., Suite 200 Washington, D.C. 20006-3402 (202) 973-4200 (202) 973-4499 (fax) Attorneys for Defendants Hearst Communications, Inc. and Mark Warren

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Case 1:11-cv-01179-RMC Document 2

Filed 08/03/11 Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that on this 3rd day of August 2011, I directed that true and correct copies of the foregoing Consent Motion to Extend Time to Answer or Respond and Points and Authorities in Support and Proposed Order be served electronically and by first class-mail, postage pre-paid, upon the following:

Larry E. Klayman Klayman Law Firm 2000 Pennsylvania Avenue, NW Suite 345 Washington, D.C. 20006

__Laura R. Handman_/s/______________ Laura R. Handman

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