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

Case 1:08-cv-00017-EGB

Document 9

Filed 04/30/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS DISTRIBUTION POSTAL CONSULTANTS, INC., Plaintiff, * v. * THE UNITED STATES, * * Defendant. * * * * * * * * * * * * Case No.: 08-17C (Judge Bruggink) * *

PLAINTIFF'S CONSENT MOTION FOR AN ENLARGEMENT OF TIME Distribution Postal Consultants, Inc. respectfully requests that this Court grant us an enlargement of time of 7 days, to and including May 8, 2008, within which to respond to Defendant's Motion for Summary Judgment and, in the Alternative, Defendant's Motion to Dismiss. Our response currently is due May 1, 2008. This is our first request for an enlargement of time for this purpose. Defendant has consented to this request. Our motion for an enlargement of time is necessary because additional time is required for undersigned counsel to gather evidence from witnesses and investigate the circumstances of the agreement between the Plaintiff and the United States in support of its Response. For the foregoing reasons, we respectfully request that the Court grant this consent motion for an enlargement of time of 7 days, to and including May 8, 2008, within which we must respond to Defendant's Motion for Summary Judgment and, in the Alternative, Defendant's Motion to Dismiss.

00038887.WPD.1

Case 1:08-cv-00017-EGB

Document 9

Filed 04/30/2008

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Respectfully submitted,

Date: April 30, 2008

/s/ Robert B. Scarlett Robert B. Scarlett

Date: April 30, 2008

/s/ Michael S. Myers Michael S. Myers SCARLETT & CROLL, P.A. 201 North Charles Street, Suite 600 Baltimore, Maryland 21201 410-468-3100 Attorneys for Plaintiff

00038887.WPD.1

Case 1:08-cv-00017-EGB

Document 9

Filed 04/30/2008

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Certificate of Service I hereby certify that on this 30th day of April, 2008, a copy of the foregoing Plaintiff's Consent Motion for an Enlargement of Time was sent via first class mail, postage prepaid, to:

Matthew H. Solomson, Esquire Trial Attorney Commercial Litigation Branch Civil Division, U. S. Department of Justice Attn: Classification Unit, 8th floor 1100 L Street, N. W. Washington, D.C. 20530

/s/ Michael S. Myers Michael S. Myers

00038887.WPD.1