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

Case 1:08-cv-00119-CCM

Document 17

Filed 09/03/2008

Page 1 of 3

IN THE UNITED STATES COURT OF FEDERAL CLAIMS CA, INC., Plaintiff, v. UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 08-119C (Judge Christine O. C. Miller)

MOTION FOR ENLARGEMENT OF TIME Pursuant to Rule 6.1, of the Rules of the United States Court of Federal Claims, Plaintiff CA, Inc., respectfully requests an enlargement of time to file its response to Defendant's Motion to Dismiss: 1. Plaintiff's response is currently due on September 8, 2008. 2. Plaintiff's counsel requests a brief enlargement of time, an additional 22 days to September 30, 2008, to respond. 3. Plaintiff's counsel seeks this request because (a) counsel of record is currently involved in arbitration proceedings being held outside the country; and (b) the parties are also attempting to resolve this matter such that a ruling on this motion may be avoided. 4. This is Plaintiff's first request for enlargement of time. 5. Plaintiff's counsel has discussed this request for enlargement with counsel for the United States, who has consented to the request.

Case 1:08-cv-00119-CCM

Document 17

Filed 09/03/2008

Page 2 of 3

Wherefore, Plaintiff respectfully requests that this Court grants its Motion for Enlargement of Time, and allow Plaintiff until September 30, 2008, to respond to Defendant's Motion to Dismiss. Respectfully submitted, s/Alan W. H. Gourley Alan W. H. Gourley CROWELL & MORING LLP 1001 Pennsylvania Avenue, NW Washington, D.C. 20004 Phone: (202) 624-2500 Fax: (202) 628-5116 Counsel for Plaintiff CA, Inc. September 3, 2008

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Case 1:08-cv-00119-CCM

Document 17

Filed 09/03/2008

Page 3 of 3

CERTIFICATE OF FILING I hereby certify that on this 3rd day of September, 2008, a copy of the foregoing Motion for Enlargement of Time was electronically filed. 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/Alan W. H. Gourley Alan W. H. Gourley CROWELL & MORING LLP 1001 Pennsylvania Avenue, NW Washington, D.C. 20004 Phone: (202) 624-2500 Fax: (202) 628-5116 Counsel for Plaintiff CA, Inc.

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