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

Case 1:94-cv-00518-EGB

Document 159

Filed 09/03/2004

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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 (Judge Bruggink)

DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME Defendant respectfully requests the Court to enlarge by 33 days, to and including October 6, 2004, 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 30, 2004,

the Court having granted defendant's previous unopposed motions for, respectively, a 29-day enlargement and a 35-day enlargement. This is defendant's third request for an Plaintiff does not

enlargement of time for this purpose. 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, therefore, so that plaintiff's counsel can

Case 1:94-cv-00518-EGB

Document 159

Filed 09/03/2004

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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 unopposed 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: Robert Morean Office of General Counsel Central Intelligence Agency September 3, 2004

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Case 1:94-cv-00518-EGB

Document 159

Filed 09/03/2004

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NOTICE OF FILING I hereby certify that on September 3, 2004, 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. Parties may access

this filing through the Court's system. I hereby further certify that on September 3, 2004, 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

/s Thomas D. Dinackus