IN THE SUPERIOR COURT OF THE DISTRICT OF COLUMBIA

Leon Stewart, et al )
)
Plaintiffs )
)
) Case No. 2016 CA 003552 B
)
v. )
) Hon. Judge Fern Flanagan Saddler
Ain K. Joseph, et al )
)
Defendants )
)
)
)

MOTION TO SUSPEND RULE 16 (c) DUE TO COVID 19 PANDEMIC

The Defendant has dropped her counterclaims and it is therefore necessary to draft a third Joint

Pretrial Statement. The above Rule requires an in person meeting. This is unwise under the

current crisis. Counsel for the Plaintiffs is 65 years old and has underlying medical conditions

that render the exposure to coronavirus to be excessively risky. It is therefore respectfully

requested that Rule 16 (c) be suspended for the drafting of the next statements.
 Certificate of Service

I certify that the Defendant has been served with a copy of this Pleading via the Case File Xpress

system.

____________________

/s/ John Hirsch, Esq.

D.C. Bar No. 1026718
 Statement Pursuant to Rule 12-l

Defendant has not consented to the relief proposed in this Motion. After ample time she has

failed to respond.

____________________

/s/ John Hirsch, Esq.

D.C. Bar No. 1026718
 IN THE SUPERIOR COURT OF THE DISTRICT OF COLUMBIA

Leon Stewart, et al )
)
Plaintiffs )
)
) Case No. 2016 CA 003552 B
)
v. )
) Hon. Judge Fern Flanagan Saddler
Ain K. Joseph, et al )
)
Defendants )
)
)
)

PROPOSED ORDER

Rule 16 (c) is suspended in order to facilitate the drafting of a Joint Pretrial Statement.

________________

Hon. Judge Fern Flanagan Saddler

Copies to all parties.

John Hirsch, Esq.

Anacostia Law
1231 B Good Hope Rd. SE
Washington, DC 20020

Ms. Ain Joseph

737 Kentucky Ave. SE
Washington, DC 20003