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IN THE UNITED STATES DISTRICT COURT 

FOR THE MIDDLE DISTRICT OF ALABAMA 

SOUTHERN DIVISION 

DEBRA BEYAH, 

Plaintiff, 

v. 

WAL-MART STORES, INC., 

Defendant. 

CIVIL ACTION NO. 1:06-CV-659 

JURY DEMANDED 

CONSENT MOTION FOR ENLARGEMENT OF TIME 

TO ANSWER OR OTHERWISE RESPOND TO PLAINTIFF’S COMPLAINT 

 Defendant Wal-Mart Stores, Inc. (“Defendant” or “Wal-Mart”), with the consent of Plaintiff 

Debra Beyah (“Plaintiff”), respectfully moves the Court for a 14-day extension of time, through and 

including September 5, 2006, to answer or otherwise respond to Plaintiff’s Complaint. In support of 

this motion, Defendant respectfully shows the Court as follows: 

1. 

 On August 2, 2006, Wal-Mart was served with a copy of the Summons and Complaint in 

this action. (Docket (“Dock.”) No. 4.) Pursuant to Fed. R. Civ. P. 6 and Fed. R. Civ. P. 12, 

Defendant’s answer or other response to Plaintiff’s Complaint is currently due on August 22, 2006. 

(See also Dock. No. 4.) 

2. 

 Good cause exists for extending the time within which Wal-Mart may answer or otherwise 

respond to Plaintiff’s Complaint, as Wal-Mart requires limited additional time to investigate the 

allegations contained in Plaintiff’s Complaint and to prepare its responsive pleading. If the Court 

Case 1:06-cv-00659-CSC Document 5 Filed 08/10/2006 Page 1 of 3
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grants Defendant’s request, Defendant’s response to Plaintiff’s Complaint would be due on or 

before September 5, 2006. 

3. 

 Pursuant to Fed. R. Civ. P. 6(b)(1), Defendant makes this request prior to the expiration 

of the original period within which to respond to Plaintiff’s Complaint. 

4. 

 Counsel for Wal-Mart conferred with Plaintiff’s counsel, Temple D. Trueblood, and 

counsel for Plaintiff consented to the requested enlargement of time. 

 WHEREFORE, Defendant respectfully requests that the Court grant a 14-day extension 

of time, through and including September 5, 2006, for Defendant to answer or otherwise respond 

to Plaintiff’s Complaint in the above-referenced case. 

 This 9th day of August 2006. 

s/ Charlotte K. McClusky, Esq.

 Charlotte K. McClusky 

ASB-5296A57M 

 Attorney for Wal-Mart Stores, Inc. 

LITTLER MENDELSON 

A Professional Corporation 

 3348 Peachtree Road, NE 

 Suite 1100 

 Atlanta, GA 30326-1008 

 Telephone: (404) 233-0330 

 Facsimile: (404) 233-2361 

 Email: cmcclusky@littler.com

 

Case 1:06-cv-00659-CSC Document 5 Filed 08/10/2006 Page 2 of 3
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IN THE UNITED STATES DISTRICT COURT 

FOR THE MIDDLE DISTRICT OF ALABAMA 

SOUTHERN DIVISION 

DEBRA BEYAH, 

Plaintiff, 

v. 

WAL-MART STORES, INC., 

Defendant. 

CIVIL ACTION NO. 1:06-CV-659 

JURY DEMANDED 

CERTIFICATE OF SERVICE 

I hereby certify that on August 9, 2006, I electronically filed the foregoing Consent 

Motion For Enlargement Of Time To Answer Or Otherwise Respond To Plaintiff’s Complaint 

with the Clerk of the Court using the CM/ECF system which will provide notice to the 

following: Ann C. Robertson, Temple D. Trueblood, and Bobbie S. Crook. 

s/ Charlotte K. McClusky, Esq.

ASB-5296A57M 

Attorney for Wal-Mart Stores, Inc. 

LITTLER MENDELSON, P.C. 

3348 Peachtree Road, NE 

Suite 1100 

Atlanta, Georgia 30326-1008 

Telephone: (404) 233-0330 

Facsimile: (404) 233-2361 

E-mail: cmcclusky@littler.com

Firmwide:81374945.1 015602.4972 

Case 1:06-cv-00659-CSC Document 5 Filed 08/10/2006 Page 3 of 3