要求暫停訴訟的動(dòng)議（樣本—簡(jiǎn)約式）
IN THE SUPERIOR COURT FOR
THE DISTRICT OF COLUMBIA
Civil Division
China Import & Export Corporation *
111 Fuxing Road *
Beijing, China 100014 *
Plaintiff * Case No. CA 05-11111
Vs. * Calendar #12
Holy International, Inc. * Judge Clir
51 Iraq Street, Suite 1000 *
Chicago, IL 30012 *
Defendant *
CONSENT MOTION TO CONTINUE TRIAL
AND MEMORANDUM IN SUPPORT
COMES NOW counsel for Plaintiff, with consent by counsel for Defendant,
pursuant to SCR General Court Rule 101, and hereby moves the Court to continue the
trial scheduled on June 1, 2005, for the following specific and sufficient reasons:
Plaintiff’s chief trial counsel and almost all of his litigation support staff are
gravely ill due to an unidentified contagious virus and have just been admitted to
Angel Hospital in Washington, D.C. It appears that it is necessary to continue the
trial scheduled for June 1, 2005, since Plaintiff’s chief trial counsel and his trial team
are currently being quarantined and monitored for possible infection with SARS, and
it is currently unknown when they will be released and cleared for work. Due to
this unforeseen situation, both parties by and through counsel have agreed to have
this matter continued to a future date. Counsel for Plaintiff and Defendant have
selected the following three alternative dates for trial, July 1, 2005, August 1, 2005,
or September 1, 2005.
WHEREFORE, the parties respectfully request that this Court grant this Consent
Motion to Continue the Trial.
Respectfully submitted,
_____________________ _________________________
Robert M. Lee, Esq. Dick B. Chiney, Esq.

Attorneys for Plaintiff Attorney for Defendant
China Import & Export Corporation 567 Putnam Parkway
666 West Main Boulevard Suite 112
Washington, D.C. 20001 Chicago, IL 30001
(202) 123-5678 (202) 876-5431
POINTS AND AUTHORITIES
1. SCR General Court Rule 101.
2. Dumb v. Connie, 123 A.3d 507 (D.C. App. 1993).
3. This Court’s general preference for disposing of cases on the merits.
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and accurate copy of the foregoing Consent
Motion, Memorandum of Points and Authorities in support thereof, and Proposed
Order were mailed first class, postage prepaid this ______ day of May, 2005 to the
parties listed below:
Dick B. Chiney, Esq.
Attorney for Defendant
567 Putnam Parkway
Suite 112
Chicago, IL 30001
_____________________
Robert M. Lee, Esq.
Attorneys for Plaintiff
China Import & Export Corporation