Free Motion for Extension of Time to File Response/Reply - District Court of Federal Claims - federal

Case 1:07-cv-00589-ECH

Document 12

Filed 02/20/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS JEFFREY B. KING, SCOTT A. AUSTEN, ) KEVIN J. HARRIS, AND JOHN J. HAYS, ) ) Plaintiffs, ) ) v. ) ) THE UNITED STATES, ) ) Defendant. )

No. 07-589C (Judge Hewitt)

DEFENDANT'S MOTION FOR AN ENLARGEMENT OF TIME Pursuant to Rules 6(b) and 6.1 of the Rules of the United States Court of Federal Claims ("RCFC"), defendant, the United States, respectfully requests a 14-day enlargement of time, to and including March 10, 2008, to file its reply brief in support of its motion to dismiss. Our reply is currently due on February 25, 2009. This is defendant's first request for an enlargement of time for this purpose. Defendant's counsel has called and left a message with plaintiffs' counsel about this enlargement of time, however, counsel was not available. The enlargement is requested because undersigned counsel of record for defendant requires additional time to confer and coordinate our reply brief with the interested agency, the Federal Bureau of Investigation. The enlargement is also requested because of counsel of record's current workload, which includes drafting a motion to remand in Former Employees of Invista SARL v. Department of Labor, Court of International Trade No. 2007-160, due February 24, 2008; and responding to complaints in Oriska Insurance Company v. United States, Court of Federal Claims No. 2007-768, due February 29, 2008 and Treslyn C. Patterson v. United States, Court of Federal Claims No. 2009-6, due March 3, 2008. For the foregoing reasons, defendant respectfully requests that the Court grant its motion

Case 1:07-cv-00589-ECH

Document 12

Filed 02/20/2008

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for an enlargement of time of 14 days, to and including March 10, 2008, within which to file its reply brief in support of its motion to dismiss. Respectfully submitted,

PETER D. KEISLER Assistant Attorney General JEANNE E. DAVIDSON Director

/s/ Martin F. Hockey MARTIN F. HOCKEY, JR. Assistant Director /s/ Carrie A Dunsmore CARRIE A. DUNSMORE Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 1100 L Street, N.W., 8th Floor Washington, D.C. 20530 Tel: (202) 305-7576 Fax: (202) 514-8624 February 20, 2008 Attorneys for Defendant

Case 1:07-cv-00589-ECH

Document 12

Filed 02/20/2008

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Certificate of Filing I hereby certify that on this 20th day of February, 2008, a copy of "Defendant's Unopposed Motion For An Enlargement Of Time" was filed electronically. I understand that notice of this filing will be sent to all parties by operation of the Court's electronic filing system. Parties may access this filing through the Court's system. /s/Carrie A. Dunsmore Carrie A. Dunsmore