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

Case 1:03-cv-02794-TCW

Document 70

Filed 08/02/2006

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS

ACCEPTANCE INSURANCE COMPANIES INC., Plaintiff, v. THE UNITED STATES OF AMERICA, Defendant.

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CASE NO. 03-2794 Judge Thomas C. Wheeler

PLAINTIFF'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME Plaintiff Acceptance Insurance Companies Inc., by and through its undersigned counsel of record and pursuant to Rule 6.1 of the Rules of the Unites States Court of Federal Claims, files this Unopposed Motion for Enlargement of Time requesting an enlargement from August 14 to August 31, 2006 to respond to the inquiry raised in the Court's July 31, 2006 Opinion and Order regarding the federal district court to which the above-referenced case should be transferred. In support of this Unopposed Motion, Plaintiff states as follows: The undersigned Plaintiff's counsel is scheduled to be on a family vacation away from Washington, D.C. from August 7 through August 19, 2006. The requested enlargement will afford counsel and his clients the opportunity upon his return to fully consider available options regarding the transfer of this case, as well as the possible appeal of the Court's July 31, 2006 Order. For these reasons, Plaintiffs Acceptance Insurance Companies Inc. respectfully requests an enlargement of time from August 14 to August 31, 2006 to respond to the Court's July 31, 2006 Order. The undersigned certifies that he discussed the filing of this motion and the relief requested herein with Defendant's counsel David Stinson. Mr. Stinson has authorized the

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Case 1:03-cv-02794-TCW

Document 70

Filed 08/02/2006

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undersigned to represent that the United States does not oppose the filing of this Motion or the requested enlargement of time. Dated: August 2, 2006 Respectfully Submitted,

/s/ Lewis S. Wiener, Esq. SUTHERLAND ASBILL & BRENNAN LLP 1275 Pennsylvania Avenue, NW Washington, D.C. 20004 202.383.0140 - phone 202.637.3593 - fax Counsel for Plaintiff Acceptance Insurance Companies Inc. OF COUNSEL: Ronald Massumi SUTHERLAND ASBILL & BRENNAN LLP 1275 Pennsylvania Avenue, NW Washington, D.C. 20004 202.383.0100 Patrick Griffin Kutak Rock, LLP The Omaha Building 1650 Farnam Street Omaha, NE 68102-2186 402.346.6000

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