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

Case 1:07-cv-00686-LJB

Document 13

Filed 01/14/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS CASE NO. 07-686C (Judge Bush) JEM TRANSPORT, INC., Plaintiff, v. UNITED STATES OF AMERICA, Defendant. _______________________________/ JEM TRANSPORT, INC.'S MOTION TO ENLARGE TIME TO FILE ANSWER AND AFFIRMATIVE DEFENSES TO COUNTERCLAIM Plaintiff, JEM TRANSPORT, INC. ("JEM TRANSPORT"), a Florida Corporation, hereby files this motion to enlarge time to file answer and affirmative defenses to the Counterclaim filed by the UNITED STATES OF AMERICA (hereinafter the "Post Office"), and in support states as follows: 1. The Post Office filed a counterclaim against JEM TRANSPORT that includes allegations regarding HCR 33434 that the undersigned does not have information sufficient to answer. 2. The undersigned's client is out of town until the end of January 2008, and is unavailable to confer regarding the factual assertions made therein. 3. Thus, the undersigned will require an additional twenty (20) days, until and including February 5, 2008, within which to respond to the Post Office's counterclaim. 4. This extension is sought in good faith and not for delay.

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Case 1:07-cv-00686-LJB

Document 13

Filed 01/14/2008

Page 2 of 2

5.

The undersigned has contacted counsel for the Post Office, but she was unavailable at the time of that contact.

WHEREFORE, JEM TRANSPORT respectfully requests an extension of time until and including February 5, 2008 to respond to the Counterclaim in this matter. Respectfully Submitted, HANKINS & ATOR, P.L. Attorneys for Plaintiffs 4600 Military Trail, Suite 217 Jupiter, FL 33458 (561) 721-3890; (561) 721-3889 (fax) [email protected] www.hankinsator.com

By:

____________________________ ROBYN S. HANKINS FLORIDA BAR NO. 0008699

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on January 17, 2008, I electronically filed the foregoing document with the Clerk of Court using CM/ECF. I understand that notice of this filing will be sent to all parties by operation of the Court's electronic filing system. The parties may access this filing through the Court's system.

_______________________________ ROBYN S. HANKINS

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