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

Case 1:06-cv-00508-LJB

Document 16

Filed 10/27/2006

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS KEITH DOHSE, Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) CASE NO. 06-508C

(Judge Lynn J. Bush)

PLAINTIFF'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME FOR PLAINTIFF TO FILE HIS RESPONSE TO DEFENDANT'S MOTION TO DISMISS IN PART Pursuant to Rule 6.1 of the Rules of the United States Court of Federal Claims, Plaintiff Keith Dohse respectfully requests an enlargement of time of twenty-five (25) days, to and including November 27, 2006, for the Plaintiff to submit his response to Defendant's Motion to Dismiss in Part. Plaintiff's response is presently due on November 2, 2006. Defendant and Plaintiff have conferred about this Motion, and Defendant consents to this Motion, which is Plaintiff's first request for an enlargement of time for this purpose. This request is being made because the attorney of record for Plaintiff Keith Dohse, Howard N. Epstein, has been occupied with numerous trials, depositions, and appellate arguments in other matters since his receipt of Defendant's Motion to Dismiss in Part, all of which matters have precluded Plaintiff's attorney from researching and briefing the issues raised in Defendant's Motion. WHEREFORE, Plaintiff Keith Dohse respectfully requests that this unopposed Motion for an Enlargement of Time for the Plaintiff to file his response to Defendant's Motion to Dismiss in Part be granted. Dated this 27th day of October, 2006. Respectfully submitted, KEITH DOHSE, Plaintiff, By: /s/ Howard N. Epstein Howard N. Epstein, #21173 MARKS CLARE & RICHARDS, L.L.C. 11605 Miracle Hills Drive, Suite 300 Omaha, NE 68154-8005 (402) 492-9800 (402) 492-9336 (Fax) [email protected] Attorneys for Plaintiff

Case 1:06-cv-00508-LJB

Document 16

Filed 10/27/2006

Page 2 of 2

CERTIFICATE OF SERVICE I hereby certify that on October 27, 2006, I electronically filed the foregoing with the Clerk of the United States Court of Federal Claims using the CM/ECF system which sent notification of such filing to the following: STEPHEN D. LOBAUGH CIVIL PRACTICE SECTION - LAW DEPARTMENT UNITED STATES POSTAL SERVICE 475 L'ENFANT PLAZA, S.W. ROOM 6333 WASHINGTON, D.C. 20260-1127

/s/ Howard N. Epstein Howard N. Epstein
Y:\WDOX\CLIENTS\16138\000\plea\EA4820.DOC

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