Case 1:09-cv-01709-RMC Document 2 Filed 10/05/2009 Page 1 of 4

UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

TAYLOR PRICE,

Plaintiff
Civil Case No. 09-cv-01709-RMC
v.

KIMBERLY, INC. d/b/a MR. SMITH’S OF

GEORGETOWN & MR. SMITH’S
MANAGEMENT COMPANY, INC. d/b/a
MR. SMITH’S OF GEORGETOWN,

Defendant.

JOINT MOTION TO EXTEND TIME TO FILE RESPONSIVE PLEADING

Plaintiff Taylor Price (“Price”) and Defendants Kimberly, Inc. d/b/a Mr. Smith’s of

Georgetown & Mr. Smith’s Management Company, Inc. d/b/a Mr. Smith’s of Georgetown

(together “Mr. Smith’s”), by and through their respective attorneys, petition this Court for an

extension of time within which Mr. Smith’s may file a pleading responsive to the Complaint in

this action. In support of this petition, Price and Mr. Smith’s state as follows:

1. Plaintiff filed a Complaint against Mr. Smith’s in this Court, on September 9,

2009.

2. Mr. Smith’s was served a copy of the Complaint on or about September 17, 2009.

3. Pursuant to Rule 12 of the Federal Rules of Civil Procedure, Mr. Smith’s is

required to file a pleading responsive to the Complaint in this action on or about October 7,

2009.

4. Currently, Mr. Smith’s intends to file a motion to dismiss the Complaint, at least

in part.

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5. Counsel for Plaintiff and counsel for Mr. Smith’s are currently engaged in

discussions to explore the possibility of settlement.

6. Counsel for Plaintiff and counsel for Mr. Smith’s both agree that these settlement

discussions may resolve this action in its entirety.

7. Thus, it is in the interest of judicial economy and in an effort to conserve party

resources that counsel seek an extension of the time within which Mr. Smith’s may file a

responsive pleading.

8. The parties propose that Mr. Smith’s responsive pleading be due November 7,

2009.

WHEREFORE, Plaintiff and Mr. Smith’s respectfully request that the Court extend the

time within which Mr. Smith’s may file a pleading responsive to the Complaint in this action.

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Dated: October 5, 2009

Respectfully submitted,

TAYLOR PRICE

By Counsel

By: /s/
J. Douglas Baldridge (D.C. Bar #437678)
Danielle R. Foley (D.C. Bar #464482)
Joeann E. Walker (Not Admitted in D.C.)
VENABLE LLP
575 7th Street, N.W.
Washington, D.C. 20004
Tel.: 202.344.4703
Fax: 202.344.8300

E. Elaine Gardner (D.C. Bar #271262)

WASHINGTON LAWYERS’ COMMITTEE FOR
CIVIL RIGHTS AND URBAN AFFAIRS
11 Dupont Circle, N.W.
Washington, D.C. 20036
Tel.: 202.319.1000
Fax: 202.319.1010

Attorneys for Taylor Price

KIMBERLY, INC. d/b/a MR. SMITH’S OF

GEORGETOWN & MR. SMITH’S MANAGEMENT
COMPANY, INC. d/b/a MR. SMITH’S OF
GEORGETOWN

By Counsel

By: /s/
Todd A. Bromberg (D.C. Bar # 472554)
Jamie A. Aycock (D.C. Bar #974343)
1776 K Street, N.W.
Washington, D.C. 20006
Tel.: 202.719-7000
Fax: 202.719-7049

Attorneys for Defendants Kimberly, Inc. d/b/a Mr.

Smith’s of Georgetown & Mr. Smith’s Management
Company, Inc. d/b/a Mr. Smith’s of Georgetown

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CERTIFICATE OF SERVICE

I hereby certify that on this 5th day of October, 2009, in accordance with Fed. R. Civ. P.
5(a), a copy of the foregoing document was served by ELECTRONIC FILING/ECF upon the
following:

J. Douglas Baldridge (D.C. Bar #437678)

Danielle R. Foley (D.C. Bar #464482)
Joeann E. Walker (Not Admitted in D.C.)
VENABLE LLP
575 7th Street, N.W.
Washington, D.C. 20004
Tel.: 202.344.4703
Fax: 202.344.8300

E. Elaine Gardner (D.C. Bar #271262)

WASHINGTON LAWYERS’
COMMITTEE FOR CIVIL RIGHTS AND
URBAN AFFAIRS
11 Dupont Circle, N.W.
Washington, D.C. 20036
Tel.: 202.319.1000
Fax: 202.319.1010

/s/______________________________
Todd A. Bromberg

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 Case 1:09-cv-01709-RMC Document 2-2 Filed 10/05/2009 Page 1 of 1

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

TAYLOR PRICE,

Plaintiff
Civil Case No. 09-cv-01709-RMC
v.

KIMBERLY, INC. d/b/a MR. SMITH’S OF

GEORGETOWN & MR. SMITH’S
MANAGEMENT COMPANY, INC. d/b/a
MR. SMITH’S OF GEORGETOWN,

Defendant.

[PROPOSED] ORDER

IT IS HEREBY ORDERED that the parties’ Joint Motion to Extend Time to File

Responsive Pleading is GRANTED and Defendants’ responsive pleading to the Complaint in

this action is due by November 7, 2009.

________________________________________
U.S. District Court Judge