Filed two days ago in Dominion v Giuliani, a motion for extension of time to reply to the Complaint. It's document # 11 on PACER, case # 1:21-cv-213 in the District Court for the District of Columbia.
Gotta hand it to Giuliani, he shows chutzpah. He actively evaded service of the Complaint for over a week, finally got caught, and then files a request for more time to reply because (1) the complaint was filed on January 25, (2) he wasn't served with the Complaint until February 10 (and whose fault is that??), and (3) his lawyer isn't up to speed yet.
His reply was originally due on March 3 2021. He's asking for that to be extended until April 7.
Here's the thing. His reply was due on March 3, and he filed his request for extension on March 4. I hope the Court throws it back in his face.