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

Case 1:03-cv-00446-EGB

Document 144

Filed 01/22/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS ) ) Plaintiffs, ) ) v. ) ) UNITED STATES, ) ) Defendant. ) ____________________________________) LEROY BISHOP, et al.,

Case No. 03-446C Senior Judge Bruggink

PLAINTIFFS' CONSENT MOTION FOR EXTENSION OF TIME TO FILE THEIR REPLY TO DEFENDANT'S OPPOSITION TO PLAINTIFF CRAIG CHALMERS'S MOTION FOR PARTIAL SUMMARY JUDGMENT AND THEIR OPPOSITION TO DEFENDANT'S CROSS-MOTION FOR SUMMARY JUDGMENT Plaintiffs, by their undersigned counsel and with the consent of Defendant, respectfully request that the Court enlarge their time from January 22, 2007, to and including February 1, 2007, to file their Reply to Defendant's Opposition to Plaintiff Craig Chalmers's Motion for Partial Summary Judgment and their Opposition to Defendant's Cross-Motion for Summary Judgment, and state, Plaintiffs' Reply to Defendant's Opposition to Plaintiff Craig Chalmers's Motion for Partial Summary Judgment and their Opposition to Defendant's Cross-Motion for Summary Judgment is currently due to be filed on or before January 22, 2007. Since December 22, 2006, when they received Defendant's Opposition to Plaintiff Craig Chalmers's Motion for Partial Summary Judgment and Defendant's Cross-Motion for Summary Judgment, Plaintiffs' counsel have been heavily involved in an immense amount of other litigation, including the following: preparation of appellants' brief in Carlsen v. United States, Case No. 2007-5011 (Fed. Cir.), which they filed on January 11, 2007; participation in an unemployment hearing in Meyer v. D.C. Coalition Against Domestic Violence, Case No.

Case 1:03-cv-00446-EGB

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Filed 01/22/2007

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ESP06105887, which lasted for five hours on January 16, 2007; and preparation of an opposition to a motion to dismiss in Hairston v. D.C. Dept. of Corrections, Case No. 2006CABSLD 007248 (D.C. Super. Ct.), which was filed on January 16, 2007; and preparation of a brief to the Equal Employment Opportunity Commission (EEOC) in Clutch v. Gutierrez, Secretary of Commerce, EEOC Docket No. 0120070609, which they filed on January 17, 2007. For these reasons and since the record is complicated and lengthy, Plaintiffs' counsel need an additional 10 days in which to complete preparation of their Reply to Defendant's Opposition to Plaintiff Craig Chalmers's Motion for Partial Summary Judgment, and their Opposition to Defendant's Cross-Motion for Summary Judgment. WHEREFORE, Plaintiffs respectfully requests that the Court grant them 10 additional days, from January 22 to and including February 1, 2007, in which to file their Reply to Defendant's Opposition to Plaintiff Craig Chalmers's Motion for Partial Summary Judgment and their Opposition to Defendant's Cross-Motion for Summary Judgment. Respectfully submitted, _________/s/____________ ALAN BANOV Alan Banov & Associates 1819 L Street, N.W. Suite 700 Washington, D.C. 20036-3830 (202) 822-9699 Fax: (202) 842-9331 [email protected] Attorney for Plaintiffs

Case 1:03-cv-00446-EGB

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Filed 01/22/2007

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CERTIFICATE OF SERVICE I hereby certify that on January 22, 2007, two copies of the foregoing Plaintiffs' Consent Motion for Extension of Time to File Their Reply to Defendant's Opposition to Plaintiff Craig Chalmers's Motion for Partial Summary Judgment and Their Opposition to Defendant's CrossMotion for Summary Judgment were served by facsimile transmission and by first-class mail, postage prepaid, upon Defendant's counsel at the following address:

Domenique Kirchner, Esq. Commercial Litigation Branch Civil Division, Classification Unit U.S. Department of Justice 1100 L Street N.W., 8th Floor Washington, D.C. 20530

_______/s/______________ ALAN BANOV