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

Case 1:94-cv-00518-EGB

Document 165

Filed 07/27/2005

Page 1 of 3

IN THE UNITED STATES COURT OF FEDERAL CLAIMS MONARCH ASSURANCE, P.L.C., and THOMAS PATRICK DENTON TAYLOR, Plaintiffs, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) ) ) ) )

No. 94-518C (Senior Judge Bruggink)

DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME Defendant respectfully requests the Court to enlarge by 72 days, to and including October 7, 2005, the time within which the parties must file a joint stipulation with regard to the letters rogatory that plaintiff will ask the Court to transmit to an appropriate court in the United Kingdom pursuant to the plaintiff's request to conduct depositions there. This

stipulation is presently due on July 27, 2005, the Court having granted defendant's previous unopposed motions for, respectively, a 29-day enlargement, a 35-day enlargement, a 33-day enlargement, a 33-day enlargement, a 37-day enlargement, a 75-day enlargement, a 74-day enlargement, and a 75-day enlargement. This is

defendant's ninth request for an enlargement of time for this purpose. Plaintiff does not oppose this motion.

Plaintiff's counsel has informed Government counsel that he has yet to hear from his client with regard to the content of the stipulation. The additional time requested is necessary,

Case 1:94-cv-00518-EGB

Document 165

Filed 07/27/2005

Page 2 of 3

therefore, so that plaintiff's counsel can confer with his client, and the parties can then prepare the joint stipulation. For the foregoing reasons, defendant respectfully requests that the Court grant this motion for an enlargement of time. Respectfully submitted, PETER D. KEISLER Assistant Attorney General /s David M. Cohen DAVID M. COHEN Director /s Thomas D. Dinackus THOMAS D. DINACKUS Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L Street, N.W. Washington, DC 20530 Tele: (202) 307-6289 Fax: (202) 514-7969 Attorneys for Defendant OF COUNSEL: Anthony Mucchetti Office of General Counsel Central Intelligence Agency July 27, 2005

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Case 1:94-cv-00518-EGB

Document 165

Filed 07/27/2005

Page 3 of 3

NOTICE OF FILING I hereby certify that on July 27, 2005, a copy of the foregoing "DEFENDANT'S UNOPPOSED MOTION FOR 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. the Court's system. I hereby further certify that on July 27, 2005, I caused to be served by United States mail (first class, postage prepaid) copies of the foregoing "DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME" addressed as follows: Raphael S. Moore, Esq. 413 F Street Davis, CA 95616 Parties may access this filing through

/s Thomas D. Dinackus