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

Case 1:01-cv-00495-EGB

Document 279

Filed 03/06/2007

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS

KENT CHRISTOFFERSON, et al.,

) ) ) Plaintiffs ) ) v. ) ) UNITED STATES OF AMERICA, ) ) Defendant. ) ) ____________________________________ )

Case No. 01-495C Judge Bruggink PLAINTIFFS' UNOPPOSED MOTION FOR ENLARGEMENT OF TIME TO FILE REPLY IN SUPPORT OF MOTION FOR LEAVE TO FILE PROPOSED SECOND AMENDED COMPLAINT

Pursuant to Rules 6(b) and 6.1 of the Rules of the United States Court of Federal Claims, Plaintiffs respectfully move the Court for an enlargement of time of 17 days, to and including April 16, within which to file Plaintiffs' Reply in Support of Motion for Leave to File Proposed Second Amended Complaint. This is Plaintiffs' first request for an enlargement of time for filing Plaintiffs' Reply in Support of Motion to Compel Further Responses. Prior to filing this Motion for Enlargement of Time, Plaintiffs' counsel contacted Defendant's counsel, who stated that he did not oppose an extension of time for Plaintiffs to file their Reply brief. Plaintiffs' counsel anticipates a need for the extension of time because of pre-hearing submissions due in a separate case on March 30 and a hearing on April 10. Accordingly, Plaintiff respectfully requests that the Court grant this Unopposed Motion for Enlargement of Time to File Plaintiffs' Reply in Support of Motion to Compel Further Responses. -1-

Case 1:01-cv-00495-EGB

Document 279

Filed 03/06/2007

Page 2 of 2

DATED: March 6, 2007

Respectfully submitted, MINAMI TAMAKI LLP

__________/s/_______________________ JACK W. LEE 360 Post St. 8th Floor San Francisco, CA 94108-4903 Telephone: (415) 788-9000 Fax: (415) 398-3887 Attorney for Plaintiffs

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