Free Motion for Extension of Time to File Response/Reply - District Court of Federal Claims - federal

Case 1:90-cv-00162-LJB

Document 630

Filed 02/26/2007

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS ) ) ) ) ) ) ) )
) ) )

STEPHEN ADAMS, et al., Plaintiffs, v. UNITED STATES OF AMERICA,
Defendant.

Case No. 90-162-C and Consolidated Cases (Judge Lynn J. Bush)

PLAINTIFFS' UNOPPOSED MOTIONS (1) TO CONSOLIDATE DEFENDANT'S MOTIONS FOR SUMMARY JUDGMENT AND (2) FOR ENLARGEMENT OF TIME Plaintiffs respectfully request, pursuant to RCFC 42 (a), that Defendant's Motion for Partial Summary Judgment with respect to criminal investigators who are employed by the Office of the Inspector General ("OIG") at the Department of Health and Human Services ("HHS") filed on December 22, 2006 and Defendant's Motion For Partial Summary Judgment with respect to criminal investigators employed by the OIG at the Department of Housing and Urban Development ("HUD") filed on February 26, 2007 be consolidated for further briefing and argument. Defendant's motions raise the identical legal and factual issues with respect to both the HHS and HUD plaintiffs, and plaintiffs submit that consideration of defendant's motions and plaintiffs' opposition should be combined in the interests of judicial economy.1 Defendant does not object to this motion.

1

Plaintiffs certainly understand that this is a consolidated case; however, plaintiffs are 1

Case 1:90-cv-00162-LJB

Document 630

Filed 02/26/2007

Page 2 of 2

Defendant filed its motion for partial summary judgment with respect to the HUD criminal investigators on February 26, 2007, and Plaintiffs' response is due on March 29, 2007. Plaintiffs' response to Defendant's motion for partial summary judgment with respect to the HHS criminal investigators is currently due on March 9, 2007. Plaintiffs move, pursuant to RCFC 6(b), the Court to extend the deadline for Plaintiffs' response to Defendant's motion for partial summary judgment with respect to the HHS criminal investigators so that plaintiffs may file one consolidated brief on March 29, 2007. Defendant does not object to this motion.

Respectfully submitted,

OF COUNSEL: Linda Lipsett

/s/ Jules Bernstein Jules Bernstein Bernstein & Lipsett 1920 L Street, N.W., Suite 602 Washington, D.C. 20036 (202) 296-1798

/s/ Edgar James Edgar James James & Hoffman 1101 17th Street, N.W., Suite 510 Washington, D.C. 20036 (202) 496-0500 Attorneys for Plaintiffs Dated: February 26, 2007

seeking consolidated treatment of the motions. 2