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

Case 1:01-cv-00351-JFM

Document 64

Filed 12/29/2005

Page 1 of 3

IN THE UNITED STATES COURT OF FEDERAL CLAIMS ____________________________________ CLEARWATER CONSTRUCTORS, INC. Plaintiff, v. THE UNITED STATES, Defendant. ____________________________________ PLAINTIFF'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME TO FILE REPLY BRIEF Plaintiff respectfully requests an enlargement of time of fourteen (14) calendar days, from January 3, 2006 to January 17, 2006, to file its reply brief in support of plaintiff's crossmotion for summary judgment. Defendant filed its Opposition to Plaintiff's Cross-Motion for Summary Judgment and Reply in Support of Defendant's Motion for Summary Judgment on December 19, 2005. Due to the demands of the holiday season, as well as busy calendars for plaintiff and its counsel, plaintiff needs additional time to reply to defendant's detailed response to plaintiff's cross-motion for summary judgment. Undersigned counsel has contacted Government counsel, who has indicated that the Government does not oppose this motion. For the foregoing reasons, defendant respectfully requests that the Court grant this motion for an enlargement of time, and extend the time for plaintiff to file its reply brief on plaintiff's cross-motion for summary judgment motion fourteen (14) days from January 3, 2006 to January 17, 2006. Dated: December 29, 2005 1 No. 01-351 (Senior Judge Merow)

Case 1:01-cv-00351-JFM

Document 64

Filed 12/29/2005

Page 2 of 3

s/ Joseph A. Camardo, Jr. Joseph A. Camardo, Jr. By Kevin M. Cox 127 Genesee Street Auburn, New York 10321 Tel: (315) 252-3846 Fax: (315) 252-3508 Attorney for Plaintiff

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Case 1:01-cv-00351-JFM

Document 64

Filed 12/29/2005

Page 3 of 3

CERTIFICATE OF SERVICE I certify under penalty of perjury that on December 29, 2005, I caused to be served by United States Mail (First Class, postage prepaid) a copy of Plaintiff's Unopposed Motion for Enlargement of Time to File Reply Brief to: J. Reid Prouty Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor, 1100 L Street Washington, DC 20530

s/ Kevin M. Cox Kevin M. Cox

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