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

Case 1:08-cv-00006-RHH

Document 12

Filed 06/23/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS TRESLYN C. PATTERSON, Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 08-6C (Sr. Judge Hodges, Jr.)

DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Pursuant to Rules 6(b) and 6.1 of the Rules of the United States Court of Federal Claims ("RCFC"), defendant, the United States, respectfully requests a 14-day enlargement of time, to and including July 17, 2008, to file its reply brief in support of its motion to dismiss the complaint. Our response is currently due on July 3, 2008. This is defendant's first request for an enlargement of time for this purpose. Defendant's counsel has spoken with plaintiff's counsel about this enlargement of time. Plaintiff's counsel stated that plaintiff does not oppose this enlargement. The enlargement is requested because of counsel of record's current workload, which includes drafting a reply brief in Ann Thomas v. United States, Court of Federal Claims No. 2007-212, due July 1, 2008, and responding to plaintiff's complaint in Steven Peireira v. United States, Court of Federal Claims No. 2008-342, due July 8, 2008. In addition, counsel of record will be out of the office on vacation from June 30, 2008 - July 6, 2008. For the foregoing reasons, defendant respectfully requests that the Court grant its motion for an enlargement of time of 14 days, to and including July 17, 2008, within which to file its reply brief in support of its motion to dismiss the complaint.

Case 1:08-cv-00006-RHH

Document 12

Filed 06/23/2008

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Respectfully submitted,

GREGORY G. KATSAS Acting Assistant Attorney General

JEANNE E. DAVIDSON Director /s/ Kirk T. Manhardt KIRK T. MANHARDT Assistant Director /s/ Carrie A. Dunsmore CARRIE A. DUNSMORE Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 1100 L Street, N.W., 8th Floor Washington, D.C. 20530 Tel: (202) 305-7576 Fax: (202) 514-8624 June 23, 2008 Attorneys for Defendant

Case 1:08-cv-00006-RHH

Document 12

Filed 06/23/2008

Page 3 of 3

Certificate of Filing I hereby certify that on this 23rd day of June, 2008, a copy of "Defendant's Unopposed Motion For An Enlargement Of Time" was filed electronically. 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/Carrie A. Dunsmore Carrie A. Dunsmore