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

Case 1:03-cv-02794-TCW

Document 43

Filed 03/03/2006

Page 1 of 2

UNITED STATES COURT OF FEDERAL CLAIMS _________________________________________ ) ACCEPTANCE INSURANCE COMPANIES INC.,) ) Plaintiff, ) v. ) No. 03-2794C ) Judge Thomas C. Wheeler UNITED STATES OF AMERICA ) ) Defendant. ) __________________________________________) PLAINTIFF'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME Plaintiff Acceptance Insurance Companies Inc. by and through its undersigned counsel and pursuant to Rule 6 of the Rules of the United States Court of Federal Claims, files this unopposed Motion for Enlargement of Time seeking an enlargement of time from March 17, 2006 through and including March 24, 2006 to file its Response in Opposition to Defendant's Renewed Motion to Dismiss or in the Alternative for Summary Judgment (filed February 10, 2006) and to file Plaintiff's Cross Motion for Summary Judgment. In support of this Motion, Plaintiff states as follows: The undersigned counsel has a family medical situation that will require him to be absent from his office from March 13 - 17, 2006. If necessary, details regarding the medical situation, which affects the undersigned's wife, can be provided to the Court. In light of this development, the undersigned requests that the Court grant an enlargement of time from March 17 to March 24, 2006 for Plaintiff to file its Opposition to Plaintiff's February 10th Motion and to file Plaintiff's Cross-Motion for Summary Judgment. No prior requests for enlargement have been requested by the Plaintiff in this matter.

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Case 1:03-cv-02794-TCW

Document 43

Filed 03/03/2006

Page 2 of 2

The undersigned has consulted with Defendant's counsel John Williamson who consents to and does not oppose the requested enlargement of time. Dated: March 3, 2006. Respectfully submitted,

/s/Lewis S. Wiener Lewis S. Wiener SUTHERLAND ASBILL & BRENNAN LLP 1275 Pennsylvania Avenue, NW Washington, D.C. 20004 202.383.0100 Counsel for Plaintiff Acceptance Insurance Companies Inc. OF COUNSEL: Patrick Griffin Kutak Rock, LLP The Omaha Building 1650 Farnam Street Omaha, NE 68102-2186 402.346.6000 Rick Massumi Carter L. Williams SUTHERLAND ASBILL & BRENNAN LLP 1275 Pennsylvania Avenue, NW Washington, D.C. 20004 202.383.0100

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