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

Case 1:00-cv-00428-CCM

Document 125

Filed 12/17/2007

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS

INTERNATIONAL AIR RESPONSE, Plaintiff, vs. THE UNITED STATES, Defendant.

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Case No. 00-428C (Assigned to the Honorable Christine O.C. Miller) E-Filed December 17, 2007

PLAINTIFF IAR'S REQUEST FOR A TWO-DAY EXTENSION OF TIME TO FILE ITS REPLY BRIEF ON ITS APPLICATION FOR ATTORNEYS' FEES AND COSTS Plaintiff IAR's reply brief on its pending application for fees and costs was to be filed on December 17, 2007. However, plaintiff's counsel unexpectedly has to be out of town on December 17 due to a hearing that was set at the end of last week in order for a plea to be entered in a criminal case that goes back seventeen years; IAR's counsel is lead counsel in the criminal matter. The plea is to be entered in Flagstaff, Arizona, which is approximately three hours from Phoenix and, therefore, Mr. Papetti will be out of the office on December 17, returning that night. The two-day extension will allow Mr. Papetti to finalize, file and serve the brief, and is necessitated due to the unexpected press of events caused by the final negotiations of and hearing on the plea agreement. The brief thus will be filed no later than December 19, 2007.

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Case 1:00-cv-00428-CCM

Document 125

Filed 12/17/2007

Page 2 of 2

Respectfully submitted,

Date: December 17, 2007

By: s/ Randy Papetti Randy Papetti Lewis and Roca LLP 40 North Central Avenue Phoenix, Arizona 85004-4429 602-262-5337 Telephone 602-734-3865 Facsimile Attorney of Record for Plaintiff International Air Response

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