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

Case 1:08-cv-00186-NBF

Document 7

Filed 06/16/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS : : : Plaintiff : v. : : THE UNITED STATES : : Defendant. : ___________________________________ : YVONNE BROWN

Case No.: 08-186C (Judge Firestone)

CONSENT MOTION FOR EXTENSION OF TIME TO FILE 12(b)(6) RESPONSE Plaintiff respectfully move the Court, pursuant to Fed. R. Civ. P. 6 (b), for a 2 week extension of time to respond to Defendant's Motion to Dismiss. Plaintiff's response would thus be due on June 30, 2008 versus June 16, 2008 and that Defendant's reply be extended accordingly. Undersigned sought the consent of counsel for the Defendant who graciously affirmed this request. Both Counsels have therefore agreed upon this

extension, subject to the Court granting this motion. WHEREFORE, for the foregoing reasons, the Defendant respectfully request that this motion be granted and that the time for Plaintiff's Opposition be extended until June 30, 2008 and Defendant WMATA's reply to the opposition be extended subject to this Honorable Court's order. _________/s/____________ Reuben B. Collins, #459751 THE COLLINS LAW GROUP, LLC P. O. Box 1857 La Plata, MD 20646 (301)934-4366, (202) 546-7323 Attorney for Plaintiff

Case 1:08-cv-00186-NBF

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Filed 06/16/2008

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IN THE UNITED STATES COURT FOR FEDERAL CLAIMS : : : Plaintiff : v. : Case No.: 08-186C : THE UNITED STATES : : : Defendant. : ___________________________________ : YVONNE BROWN POINTS AND AUTHORITIES 1. Fed. R. Civ. P. 6(b) 2. Local Rule 7.1

_________/s/____________ Reuben B. Collins, #459751 Attorney for Plaintiff

CERTIFICATE OF SERVICE I HEREBY CERTIFY that on this 16TH day of June, 2008, a copy of the foregoing was served via electronic filing to: Roger A. Hipp Department of Justice 1100 L Street, N.W. Washington, DC 20530 Attorney for Defendant United States

______/s/___________

Reuben B. Collins, Esquire

Case 1:08-cv-00186-NBF

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Filed 06/16/2008

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IN THE UNITED STATES COURT FOR FEDERAL CLAIMS : : : Plaintiff : v. : Case No.: 08-186C : UNITED STATES OF AMERICA : : : Defendant. : ___________________________________ : YVONNE BROWN ORDER

Upon consideration of the Plaintiff's Motion for Extension of Time and good cause having been shown, it is by the Court this ______ day of ____________, 2008. Ordered, that the motion is granted. The time for Plaintiff to file his

Opposition to Defendant's Motion to Dismiss is extended until June 30, 2008 and the time for Defendant to file his Response to Plaintiff's Motion for Summary Judgment is extended until __________________.

____________________________ HONORABLE JUDGE

Copies to: Reuben B. Collins, II Collins & Talley, LLC P. O. Box 1857

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Filed 06/16/2008

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La Plata, MD 20646 Attorney for Plaintiff Keith Hopps Roger A. Hipp Department of Justice 1100 L Street, N.W. Washington, DC 20653 Attorney for Defendant