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

Case 1:07-cv-00543-EJD

Document 19

Filed 02/15/2008

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IN THE UNITED STATES COURT FOR FEDERAL CLAIMS

Maxit Designs Inc., Plaintiff, vs. United States of America, Department of Defense, and Defense Logistics Agency Defendants

) Case No. 07-543 C ) Chief Judge EDWARD J. DAMICH ) ) MOTION FOR EXTENSION OF TIME ) ) ) ) ) )

MAXIT DESIGNS' UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE ITS ANSWER TO MOTION FOR DISMISSAL AND JOINT PRELIMINARY STATUS REPORT

Plaintiff Maxit Designs Inc. moves for a sixty-day extension of time to answer, or otherwise respond to, the Motion for Dismissal filed by Defendant United States ("Government"). The answer is currently due on February 19, 2008. The Plaintiff seeks a sixty-day extension up to, and including, April 21, 2008. Defendant does not oppose this motion.

Plaintiff requests this additional time to locate attorney representatives specializing in litigation and located in the Washington D. C. area. Current legal representative does not specialize in litigation nor is her office located in Washington D.C., where the United States Court of Federal Claims where the trial will take place. Plaintiff has been in negotiations with law firms, but has formed agreement yet. Since Plaintiff is unable to respond to Defendant's Motion for Summary Judgment until suitable representation is obtained, Plaintiff (and Defendant concurring) seeks extension

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Case 1:07-cv-00543-EJD

Document 19

Filed 02/15/2008

Page 2 of 2

of time for preparation of the Joint Preliminary Status Report also. For all of these reasons, Plaintiff respectfully requests that it be granted an extension of time to answer, or otherwise respond to, the complaint up to, and including, April 21, 2008. Respectfully submitted,

s/Linda K. Hopkins Linda K. Hopkins, Attorney At Law Attorney for Plaintiff INTELLIWARE INT'L LAW FIRM 449 South Owasso Boulevard West Roseville, Minnesota 55113 (Telephone/Fax) 651-481-0177 Email: [email protected] Date: February 15, 2008

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