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

Case 1:08-cv-00017-EGB

Document 19

Filed 08/14/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS DISTRIBUTION POSTAL CONSULTANTS, INC., Plaintiff, * v. * THE UNITED STATES, * * Defendant. * * * * * * * * * * * * Case No.: 08-17C (Judge Bruggink) * *

PLAINTIFF'S CONSENT MOTION FOR AN ENLARGEMENT OF TIME Distribution Postal Consultants, Inc. respectfully requests that this Court grant an enlargement of time of twenty-one (21) days, to and including September 4, 2008, within which to file a new response and cross-motion for summary judgment pursuant to this Court's order dated June 27, 2008. The Plaintiff's motion for an enlargement of time is necessary because additional time is required for undersigned counsel to gather evidence, specifically, an e-mail correspondence identified at the deposition of James J. Crawford, a witness for the Defendant. Enclosed herewith is an e-mail to Counsel for the Defendant requesting said document. For the foregoing reasons, we respectfully request that this Court grant this consent motion for an enlargement of time of 21 days, to and including September 4, 2008, within which to file a new response and cross-motion for summary judgment.

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Case 1:08-cv-00017-EGB

Document 19

Filed 08/14/2008

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Respectfully submitted,

Date: August 14, 2008

/s/ Michael S. Myers Michael S. Myers SCARLETT & CROLL, P.A. 201 North Charles Street, Suite 600 Baltimore, Maryland 21201 410-468-3100 Attorneys for Plaintiff

00044029.WPD.1

Case 1:08-cv-00017-EGB

Document 19

Filed 08/14/2008

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Certificate of Service I hereby certify that on this 14th day of August, 2008, a copy of the foregoing Plaintiff's Consent Motion for an Enlargement of Time was sent via first class mail, postage prepaid, to:

Matthew H. Solomson, Esquire Trial Attorney Commercial Litigation Branch Civil Division, U. S. Department of Justice Attn: Classification Unit, 8th floor 1100 L Street, N. W. Washington, D.C. 20530

/s/ Michael S. Myers Michael S. Myers

00044029.WPD.1