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

Case 1:01-cv-02011-VJW

Document 4

Filed 09/05/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS JOYCE JAMES, ) ) ) ) ) ) ) ) ) ) )

Plaintiff, v. THE UNITED STATES OF AMERICA, Defendant.

No. 01-2011L Honorable Victor J. Wolski

UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME TO FILE A REPLY IN SUPPORT OF DEFENDANT'S MOTION TO DISMISS PLAINTIFF JOYCE JAMES Defendant hereby moves the Court for an enlargement of time to file its Reply in support Defendant's Motion to Dismiss Plaintiff Joyce James on jurisdictional grounds, or alternatively, for lack of standing. Defendant's Reply is currently due on September 8, 2008 in accordance with this Court's August 29, 2008 Order. Defendant requests an additional 18 days until September 26, 2008 to file the Reply. The August 29, 2008 Order noted that Plaintiff filed a letter and a purported deed for 206 Dozier Lane, Virginia Beach, Virginia in response to Defendant's Motion to Dismiss. Defendant, however, was not formally served with a copy of Plaintiff's response to the motion from Plaintiff. As a courtesy, Judge Wolski's law clerk faxed Plaintiff's letter to undersigned counsel on September 2, 2008. Defendant has not had sufficient time to evaluate Plaintiff's allegations in her response and file its Reply. Defendant has conferred with Plaintiff who does not oppose this motion. For the foregoing reasons, Defendant respectfully requests that this Court grant Defendant's motion for an enlargement of time until September 26, 2008 to file its Reply.

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Case 1:01-cv-02011-VJW

Document 4

Filed 09/05/2008

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Dated: September 5, 2008

Respectfully submitted,

Ronald J. Tenpas Assistant Attorney General Environmental & Natural Resources Division United States Department of Justice

s// Steven D. Bryant Steven D. Bryant Environmental & Natural Resources Division United States Department of Justice 601 D Street, NW, Rm. 3120 Washington, D.C. 20004 Counsel for Defendant [email protected] 202-305-0424 Of Counsel: Robert J. Smith Navy Litigation Office 720 Kennon Street Washington Navy Yard, D.C. 20374

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Case 1:01-cv-02011-VJW

Document 4

Filed 09/05/2008

Page 3 of 3

CERTIFICATE OF SERVICE

I certify that a copy of the foregoing UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME TO FILE A REPLY IN SUPPORT OF DEFENDANT=S MOTION TO DISMISS PLAINTIFF JOYCE JAMES was served this 5th day of September 2008, via overnight courier to Joyce James, 940 Maximus Street, #101, Virginia Beach, Virginia 23451, (757) 428-1798.

s// Steven D. Bryant STEVEN D. BRYANT

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