Blue Flame Medical v. Chain Bridge Bank — Joint Motion for Extension of Deadlines
- Date
- 2020-07-20
Summary
A joint motion for extension of deadlines filed June 23, 2020 as Document 13 in Blue Flame Medical LLC v. Chain Bridge Bank, N.A., John J. Brough, and David M. Evinger, Civil Action No. 1:20-cv-00658, in the U.S. District Court for the Eastern District of Virginia. The parties ask for a 14-day extension of defendants' time to respond to the complaint, to July 20, 2020, and a matching extension of plaintiff's time to oppose any motion to dismiss, to August 17, 2020. The motion states that the complaint was filed June 12, 2020, that defendants were served June 15, 2020, that defendants' counsel were retained only recently, and that the COVID-19 pandemic has disrupted working conditions. It states this is the parties' first extension request and attaches a proposed order as Exhibit A.
Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used
Cite this document
“Blue Flame Medical v. Chain Bridge Bank — Joint Motion for Extension of Deadlines.”
Original at ecf.vaed.uscourts.gov, dated 2020-07-20. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/2020-07-20-plaintiff-v-chain-bridge-bank-n-a-john-j/
, SHA-256 7e86971a734d683880b3c6576febcc390fac97da79bce19e6312d0e8a142f072.Full text
Case 1:20-cv-00658-LMB-IDD Document 13 Filed 06/23/20 Page 1 of 4 PageID# 60
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF VIRGINIA
(Alexandria Division)
BLUE FLAME MEDICAL LLC,
Plaintiff,
Civil Action No. 1:20-cv-00658
v.
CHAIN BRIDGE BANK, N.A., JOHN J.
BROUGH, and DAVID M. EVINGER,
Defendants.
JOINT MOTION FOR
EXTENSION OF DEADLINES
Pursuant to Rule 7(I) of this Court’s Local Civil Rules, Plaintiff Blue Flame Medical
LLC and Defendants Chain Bridge Bank, N.A., John J. Brough, and David M. Evinger (together
with Plaintiff, the “Parties”), by and through their respective undersigned counsel, respectfully
request a 14-day extension of Defendants’ time, to and including July 20, 2020, to answer, move
to dismiss, or otherwise respond to Plaintiff Blue Flame Medical LLC’s Complaint. The Parties
further request a 14-day extension of Plaintiff’s time, to and including August 17, 2020, to
respond to any motion to dismiss filed by Defendants. A proposed order reflecting the requested
relief is attached hereto as Exhibit A. In support of this Motion, the Parties respectfully state as
follows:
1. Plaintiff’s Complaint was filed on June 12, 2020. Each Defendant was served
with the Complaint on June 15, 2020. Unless extended, the time within which to answer, move
to dismiss, or otherwise respond to the Complaint will expire on July 6, 2020.
2. The Parties respectfully request a 14-day extension of Defendants’ time, to and
including July 20, 2020, within which to answer, move to dismiss, or otherwise respond to the
Case 1:20-cv-00658-LMB-IDD Document 13 Filed 06/23/20 Page 2 of 4 PageID# 61
Complaint. Additionally, the Parties respectfully request a corresponding 14-day extension of
Plaintiff’s time, to and including August 17, 2020, to oppose any motion to dismiss filed by
Defendants.
3. Defendants’ counsel were retained only recently and therefore require additional
time to analyze Plaintiff’s claims, to investigate the facts at issue in this matter, and to prepare an
answer, motion to dismiss, or other response to the Complaint. Additional time is also warranted
due to the disruption to working conditions caused by the ongoing COVID-19 pandemic.
4. This Motion is filed before the expiration of Defendants’ time to respond to the
Complaint.
5. This is the Parties’ first request for an extension of time.
6. The Parties waive any hearing on this Motion.
*****
WHEREFORE, the Parties jointly move that the Court enter an order, substantially in the
form attached hereto as Exhibit A, granting a 14-day extension of Defendants’ time, to and
including July 20, 2020, to answer, move to dismiss, or otherwise respond to the Complaint, as
well as a 14-day extension of Plaintiff’s time, to and including August 17, 2020, to oppose any
motion to dismiss filed by Defendants.
2
Case 1:20-cv-00658-LMB-IDD Document 13 Filed 06/23/20 Page 3 of 4 PageID# 62
Dated: June 23, 2020 Respectfully submitted,
/s/ Donald Burke
Gary A. Orseck (pro hac vice pending)
Matthew M. Madden (pro hac vice pending)
Donald Burke (VA Bar No. 76550)
Megan D. Browder (pro hac vice pending)
ROBBINS, RUSSELL, ENGLERT, ORSECK,
UNTEREINER & SAUBER LLP
2000 K Street, N.W., 4th Floor
Washington, D.C. 20006
Tel: (202) 775-4500
Fax: (202) 775-4510
dburke@robbinsrussell.com
Counsel for Defendants
/s/ Peter H. White
Peter H. White (VA Bar No. 32310)
SCHULTE ROTH & ZABEL LLP
901 Fifteenth Street, NW, Suite 800
Washington, DC 20005
Tel: (202) 729-7476
Fax: (202) 730-4520
peter.white@srz.com
Counsel for Plaintiff
3
Case 1:20-cv-00658-LMB-IDD Document 13 Filed 06/23/20 Page 4 of 4 PageID# 63
CERTIFICATE OF SERVICE
I hereby certify that on June 23, 2020, I will electronically file the foregoing with the
Clerk of Court using the CM/ECF system, which will then send a notification of such filing to
the following:
Peter H. White, Esq.
SCHULTE ROTH & ZABEL LLP
901 Fifteenth Street, NW, Suite 800
Washington, DC 20005
Tel: 202-729-7476
Fax: 202-730-4520
peter.white@srz.com
Counsel for Blue Flame Medical LLC
/s/ Donald Burke
Donald Burke (VA Bar No. 76550)
ROBBINS, RUSSELL, ENGLERT, ORSECK,
UNTEREINER & SAUBER LLP
2000 K Street, N.W., 4th Floor
Washington, D.C. 20006
Tel: (202) 775-4500
Fax: (202) 775-4510
dburke@robbinsrussell.com
File and source
- File
- gov.uscourts.vaed.477405.13.0.pdf
- Size
- 122,188 bytes
- SHA-256
- 7e86971a734d683880b3c6576febcc390fac97da79bce19e6312d0e8a142f072
- Original
- PACER (login required)