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IN THE UNITED STATES COURT OF FEDERAL CLAIMS THE TRAVELERS INSURANCE COMPANY, Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )
No. 05-1252C (Judge Lettow)
DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME Defendant respectfully requests the Court to grant an enlargement of time of seven days, to and including May 19, 2006, within which to file its reply in support of its cross-motion for summary judgment. The reply is currently due on May 12, 2006. Counsel for plaintiff has informed counsel for the defendant that he does not oppose this request for an enlargement of time. No previous enlargements of time have been requested. Counsel for the Government requests the additional time because she has other commitments that require a substantial amount of her time. In particular, counsel was in New Mexico from April 17 through April 19, 2006, to interview witnesses and review documents in Silver State Construction Co. v. United States, Fed. Cl. 05-978C. She was required to present an oral argument in Commercial Casualty Ins. Co. v. United States, Fed. Cl. No. 03-2033C, and Cincinnati Ins. Co. v. United States, Fed. Cl. No. 05-751C, on April 28, 2006. On the same date, she was required to file a supplemental brief in Peoples v. United States, Fed. Cl. No. 05-214C. On May 1, 2006, counsel was required to file a brief in Daluz v. United States, Fed. Cl. No. 05368C. Finally, on May 12, 2006, counsel is required to file a brief in SAB Construction, Inc. v. United States, Fed. Cir. No. 06-5009, which is a complex appeal from the Court's grant of summary judgment in favor of defendant.
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For the foregoing reasons, we respectfully request the Court to grant defendant's motion for an enlargement of time of seven days to file our reply in support of our motion for summary judgment. Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director
s/ Harold D. Lester, Jr. HAROLD D. LESTER, JR. Assistant Director
s/ Doris S. Finnerman DORIS S. FINNERMAN Trial Attorney Commercial Litigation Branch Department of Justice 1100 L Street, N.W. Attn: Classification Unit 8th Floor Washington, D.C. 20530 Tele: (202) 307-0300 Fax: (202) 305-7643 Attorneys for Defendant May 3, 2006