Free Motion for Extension of Time - District Court of Federal Claims - federal

Case 1:01-cv-00351-JFM

Document 66

Filed 01/13/2006

Page 1 of 3

IN THE UNITED STATES COURT OF FEDERAL CLAIMS ____________________________________ CLEARWATER CONSTRUCTORS, INC. Plaintiff, v. THE UNITED STATES, Defendant. ____________________________________ PLAINTIFF'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME TO FILE REPLY BRIEF Plaintiff respectfully requests an enlargement of time of seven (7) calendar days, from January 17, 2006 to January 24, 2006, to file its reply brief in support of plaintiff's cross-motion for summary judgment. Due to his busy schedule and unavailability during much of the past two weeks, plaintiff's principal Seth Kohn has not had adequate time to provide counsel with information needed for plaintiff's reply brief. As such, plaintiff is need of some additional time to confer with counsel and file its reply brief. Plaintiff anticipates that an additional seven (7) days should be sufficient in this regard. Undersigned counsel has contacted Government counsel, who has indicated that the Government does not oppose this motion. For the foregoing reasons, defendant respectfully requests that the Court grant this motion for an enlargement of time, and extend the time for plaintiff to file its reply brief on plaintiff's cross-motion for summary judgment motion seven (7) days from January 17, 2006 to January 24, 2006. Dated: January 13, 2006 1 No. 01-351 (Senior Judge Merow)

Case 1:01-cv-00351-JFM

Document 66

Filed 01/13/2006

Page 2 of 3

s/ Joseph A. Camardo, Jr. Joseph A. Camardo, Jr. By Kevin M. Cox 127 Genesee Street Auburn, New York 10321 Tel: (315) 252-3846 Fax: (315) 252-3508 Attorney for Plaintiff

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Case 1:01-cv-00351-JFM

Document 66

Filed 01/13/2006

Page 3 of 3

CERTIFICATE OF SERVICE I certify under penalty of perjury that on January 13, 2006, I caused to be served by United States Mail (First Class, postage prepaid) a copy of Plaintiff's Unopposed Motion for Enlargement of Time to File Reply Brief to: J. Reid Prouty Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor, 1100 L Street Washington, DC 20530

s/ Kevin M. Cox Kevin M. Cox

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