Free Response to Motion - District Court of Federal Claims - federal

Case 1:04-cv-01665-CFL

Document 13

Filed 04/21/2005

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS -----------------------------------------------------------------------X NOVA CASUALTY COMPANY, No. 04-1665C Plaintiff, (JUDGE LETTOW) -againstTHE UNITED STATES, Defendant. -----------------------------------------------------------------------X Electronically Filed April 21, 2005

PLAINTIFF'S RESPONSE TO DEFENDANT'S MOTION FOR ENLARGEMENT OF TIME For purposes of clarity, plaintiff Nova Casualty Company submits this response to the motion for enlargement of time filed by defendant, the United States of America. On two previous occasions, defendant's counsel has requested consent from the undersigned for enlargements of time for the purpose of responding to the plaintiff's complaint. On both occasions, consent was freely granted. The defendant's counsel recently requested the undersigned's consent to an enlargement of time to respond to the plaintiff's amended complaint, and to reply to plaintiff's opposition to defendant's motion to dismiss plaintiff's complaint. The plaintiff does not oppose an enlargement of time to reply to plaintiff's opposition to defendant's motion to dismiss the plaintiff's complaint. However, plaintiff consents to an enlargement of time for the purpose of answering the amended complaint, only. The plaintiff wishes to proceed to the merits of its claim against the defendant, and opposes the enlargement of time that will only be used to avoid answering on the merits.

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Case 1:04-cv-01665-CFL

Document 13

Filed 04/21/2005

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Respectfully submitted,

s/ Neil B. Connelly Neil B. Connelly, Esq. Attorney for Plaintiff 99 Church Street, 4th Floor White Plains, New York 10601 914-328-4100 Fax 914-684-0401 Electronically filed: April 21, 2005.

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Case 1:04-cv-01665-CFL

Document 13

Filed 04/21/2005

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CERIFICATE OF SERVICE I hereby certify that on the 21st day of April 2005, a copy of the foregoing "PLAINTIFF'S RESPONSE TO DEFENDANT'S MOTION FOR ENLARGEMENT OF TIME" was filed electronically with the U.S. Court of Federal Claims. I understand that notice of this filing will be sent to all parties through the Court's electronic filing system. Parties may access this filing through the Court's electronic filing system. s/ Neil B. Connelly

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