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

Case 1:08-cv-00022-ECH

Document 8

Filed 05/22/2008

Page 1 of 1

IN THE UNITED STATES COURT OF FEDERAL CLAIMS SUNSHINE DEVELOPMENT, INC. ) ) Plaintiff, ) ) v. ) ) THE UNITED STATES ) ) Defendant. ) __________________________________________)

Fed. Cl. No. 08-22C (Judge Hewitt)

PLAINTIFF'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME TO RESPOND TO DEFENDANT'S MOTION TO STAY THE PROCEEDINGS

Pursuant to RCFC 6.1 and 6(b), Plaintiff respectfully requests an additional ten (10) days from May 23, 2008 until June 2, 2008 to respond to Defendant's Motion to Stay the Proceedings. This is Plaintiff's first request for additional time to respond to the motion. Plaintiff requests additional time in order to discuss the stay with its counsel and decide the appropriate course of action. This additional time will also allow Plaintiff's counsel to discuss proceedings in the United States District Court for the Middle District of Pennsylvania with the United States Attorney handling that case. Plaintiff's counsel has discussed this request for additional time with Defendant's counsel and Defendant's counsel has no objection. Dated: May 22, 2008 Respectfully submitted, s/ Stephen B. Hurlbut______ Stephen B. Hurlbut, Esquire AKERMAN SENTERFITT WICKWIRE GAVIN 8100 Boone Boulevard, Suite 700 Vienna, Virginia 22182 (703)790-8750 (phone) (703)448-1801 (fax) E-mail: [email protected]