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

Case 1:94-cv-00518-EGB

Document 158

Filed 07/30/2004

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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 35 days, to and including September 3, 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 motion for a 29-day enlargement. This is defendant's second

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, therefore, so that plaintiff's counsel can confer with his client, and the parties can then prepare the

Case 1:94-cv-00518-EGB

Document 158

Filed 07/30/2004

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joint stipulation.

In addition, Government counsel will be

out of the office on previously-scheduled annual leave from August 20, 2004 through August 28, 2004. 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 July 30, 2004

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Case 1:94-cv-00518-EGB

Document 158

Filed 07/30/2004

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NOTICE OF FILING I hereby certify that on July 30, 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. filing through the Court's system. I hereby further certify that on July 30, 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 Parties may access this

/s Thomas D. Dinackus