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

Case 1:07-cv-00815-TCW

Document 11

Filed 04/11/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS CALL HENRY, INC., Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 07-815C (Judge Wheeler)

DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME Pursuant to Rule 6.1 of the Rules of the United States Court of Federal Claims, defendant, the United States, respectfully requests a 21-day extension of time, to and including May 9, 2008, to file a reply brief in support of our pending motion to dismiss the complaint filed by plaintiff, Call Henry, Inc. Our reply brief currently is due on April 18, 2008. This is our first request for an enlargement of time for this purpose. Counsel for the parties have discussed this motion and its request for relief, and plaintiff's counsel has represented that plaintiff does not oppose this request. The requested enlargement is necessary because defendant's counsel has been out of the office to perform family responsibilities associated with the birth of a child. We anticipate that the 21-day enlargement of time will provide sufficient time for defendant to file a reply brief.

Case 1:07-cv-00815-TCW

Document 11

Filed 04/11/2008

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For these reasons, we respectfully request that the Court grant this motion for a 21-day enlargement of time, to and including May 9, 2008, for the United States to file a reply brief in support of the pending motion to dismiss. Respectfully submitted,

JEFFREY S. BUCHOLTZ Acting Assistant Attorney General

JEANNE E. DAVIDSON Director

s/Patricia M. McCarthy PATRICIA M. MCCARTHY Assistant Director

s/Douglas G. Edelschick DOUGLAS G. EDELSCHICK Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L. Street, N.W. Washington, DC 20530 Tel: (202) 353-9303 April 11, 2008 Attorneys for Defendant

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Case 1:07-cv-00815-TCW

Document 11

Filed 04/11/2008

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that on April 11, 2008, a copy of 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. Parties may access this filing through the Court's system.

s/Douglas G. Edelschick

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