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

Case 1:00-cv-00644-NBF

Document 142

Filed 01/29/2007

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS

WILLIAM A. CLARK, JAMES P. DAVERN, ROBERT E.FREEBURG, WILLIE R. JOHNSON, ROBERT A. MUSTIN, JOHN DOES 1 through 4, and JANE DOES 1 through 3, individually, and on behalf of all other similarly situated, Plaintiffs, v. THE UNITED STATES, Defendant.

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No. 00-644 (Judge Firestone)

UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME TO FILE PLAINTIFFS' BRIEF IN OPPOSITION TO THE GOVERNMENT'S MOTION TO DISMISS Pursuant to Rule 6.1 of the Rules of the Court of Federal Claims, Plaintiffs respectfully submit this unopposed motion for an enlargement of time of 5 court days, up to and including February 12, 2007, within which to file their brief in opposition to the government's motion to dismiss. Pursuant to the Court's Order dated November 15, 2006, Plaintiffs were to submit the above-mentioned brief on February 5, 2007. Plaintiffs have not previously sought an extension for submission of this brief. Counsel for Plaintiffs has discussed this motion with Defendant's counsel, and Defendant's counsel has consented to this short extension. Plaintiffs seek this short enlargement of time, owing to conflicting commitments, and in order to fully develop its arguments in response to Defendant's Motion to Dismiss, which involve discussion of several important constitutional concerns. Given the brief time period covered by the extension, there will be no undue delay in the advancement of this litigation.

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Case 1:00-cv-00644-NBF

Document 142

Filed 01/29/2007

Page 2 of 2

For the foregoing reasons, Plaintiffs respectfully request that the Court grant this request for an enlargement of time of 5 court days for the Plaintiffs to submit their Opposition to Defendant's Motion to Dismiss.

Respectfully submitted,

/s Helen K. Michael Robert H. Shulman Helen K. Michael HOWREY LLP 1299 Pennsylvania Avenue, N.W. Washington, D.C. 20004 Tel: (202) 783-0800 Fax: (202) 383-6610 Richard T. Dorman CUNNINGHAM, BOUNDS, VANCE, CROWDER, and BROWN, LLC 1601 Dauphin Street Mobile, Alabama 36660 Tel: (334) 471-6191 Fax: (334) 479-1031 Charles J. Cooper David Thompson COOPER & KIRK, P.L.L.C. 1500 K Street, N.W., Ste. 200 Washington, DC 2005 Tel: (202) 220-9600 Fax: (202) 220-9601

Counsel for Plaintiffs Dated: January 29, 2007

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