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

Case 1:08-cv-00020-TCW

Document 17

Filed 06/16/2008

Page 1 of 3

UNITED STATES COURT FOR FEDERAL CLAIMS MARK S. ZAID, P.C. MARK S. ZAID, ESQ. 1250 Connecticut Avenue, N.W. Suite 200 Washington, D.C. 20036 Plaintiffs v. UNITED STATES OF AMERICA Defendant * * * * * * * * * * * * * * * * * * * * * * * * *

No. 08-20 C Judge Thomas C. Wheeler

PLAINTIFFS' UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Pursuant to the Rules of the United States Court of Federal Claims 6(b) and 6.1, Plaintiffs requests an enlargement of time of thirty-two days, to and including July 21, 2008, within which to submit its response to the Government's motion to dismiss. Plaintiff's opposition is currently due on June 19, 2008. This is Plaintiffs' first request for an enlargement of time for this purpose. Counsel for the Government has consented to Plaintiffs' request for this enlargement of time. Since the Government filed its motion to dismiss Plaintiffs' complaint, counsel for plaintiffs has been occupied with other matters including the settlement of a contentious family law matter, bringing a new case for copyright infringement, and working on several transactional matters for corporate clients. At the same time, plaintiff Mark Zaid was out of town on business travel June 1 - 8, 2008, and he is out of town the week of June 16 - 20, 2008 as well. Mr. Zaid, an attorney, also had a hearing before the Defense Office of Hearings and Appeals, and he has been working on several active

Case 1:08-cv-00020-TCW

Document 17

Filed 06/16/2008

Page 2 of 3

litigation matters for clients with cases pending against myriad government agencies. Counsel for Plaintiffs requests the thirty-two day enlargement of time as he and his clients need additional time to meet and prepare a response to the motion to dismiss. And because counsel anticipates that he will file a motion for summary judgment, he and his clients need time to prepare that pleading so that it can be filed with the opposition to the Government's motion to dismiss. For the reasons stated above, counsel for the Plaintiffs respectfully requests that the court grant this motion for an enlargement of time.

s/ Eric H. Imperial _______________________________ Eric H. Imperial (D.C. Bar #427139) 815 Connecticut Avenue, N.W.; Ste. 220 Washington, DC 20006 (202) 457-1280 (202) 595-1986 (fax) [email protected] Date: June 16, 2008

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Case 1:08-cv-00020-TCW

Document 17

Filed 06/16/2008

Page 3 of 3

Certificate of Service

I hereby certify that on June 16, 2008, I electronically filed a copy of the foregoing MOTION FOR ENLARGEMENT OF TIME with the United States Court of Federal Claims. Notice of this filing will be sent to all parties by operation of the court's electronic filing system, and all parties can access this filing through that filing system.

s/ Eric H. Imperial _________________________________ Eric H. Imperial (D.C. Bar #427139) 815 Connecticut Avenue, N.W.; Ste. 220 Washington, DC 20006 (202) 457-1280 (202) 595-1986 (fax) [email protected]

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