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

Case 1:03-cv-01216-JPW

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Filed 10/27/2003

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS PLACID HOLDING COMPANY, Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 03-1216C (Judge Wiese)

DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME Defendant respectfully requests an enlargement of time of 24 days, from October 28, 2003, to and including, November 21, 2003, within which to reply to plaintiff's cross motion. Plaintiff's counsel has informed us that plaintiff does not oppose. Since plaintiff filed its brief, defendant's counsel has been required to devote a significant portion of his time to other matters pending in this Court, and the court of appeals. These matters include: traveling to California and Hawaii for two weeks of depositions in Christofferson v. United States, No. 01-495C (Fed. Cl.), and Chang v. United States, No. 01495C; preparing a brief in Valero v. United States, No. 03-1916C (Fed. Cl.); preparing for and attending depositions in LaGloria v. United States, No. 02-465C (Fed. Cl.); and responding to a court order and delivering an oral argument in Christopher Village v. United States, No. 02-5188 (Fed. Cir). Within the next 28 days, defendant's counsel is scheduled to do the following: prepare briefs in Atofina v. United States, No. 03-538C (Fed. Cl.) (due October 27, enlargement request pending); Kern v. United States, No. 03-1916C (Fed. Cl.) (due November 7); and Briggs v. United States, No. 01-552C (Fed. Cl.) (due November 17, 2003); deliver an oral argument in Flint Hills v. United States, No. 02-462C (Fed. Cl.) (October 29); participate in a conference in

Case 1:03-cv-01216-JPW

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Calcasieu v. United States, No. 02-1219C (Fed. Cl.) (November 6); and prepare for and travel to California to take approximately 20 depositions in Christofferson v. United States, No. 01-495C (Fed. Cl.)(November 10-14). For these reasons, defendant respectfully requests an enlargement of time of 24 days, from October 28, 2003, to and including, November 21, 2003, within which to reply to plaintiff's cross motion. Respectfully submitted, PETER D. KEISLER Assistant Attorney General s/ David M. Cohen DAVID M. COHEN Director OF COUNSEL: BERNARD A. DUVAL Counsel HOWARD M. KAUFER Assistant Counsel Office of General Counsel Defense Energy Support Center Ft. Belvoir, VA s/ Steven J. Gillingham STEVEN J. GILLINGHAM Senior Trial Counsel KYLE CHADWICK Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 1100 L Street, 8th Floor Washington, D.C. 20530 Tele: (202) 616-2311 Fax: (202) 353-7988 Attorneys for Defendant

October 24, 2003

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Case 1:03-cv-01216-JPW

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Filed 10/27/2003

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CERTIFICATE OF FILING I hereby certify that on October 27, 2003, a copy of the foregoing was filed electronically. I understand that notice of this filing will be sent to all parties by operation of the Court's electronic filing system. Parties may access this filing through the Court's system.

s/Steven J. Gillingham