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

Case 1:07-cv-00790-ECH

Document 16

Filed 09/02/2008

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS ZORAIDA GONZALEZ, et al., Plaintiffs, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) )

No. 07-790C (Judge Hewitt)

DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME Pursuant to Rule 6.1 of the Rules of this Court, defendant, the United States, respectfully requests a 7-day enlargement of time, to and including September 9, 2008, within which to respond to plaintiffs' partial motion for summary judgment with respect to the driving-time issue and proposed findings of uncontroverted fact accompanying the motion. Currently, our responses are due on September 2, 2008. This is the defendant's first request for an enlargement of time for this purpose. Counsel for plaintiffs indicated that plaintiffs will not oppose this motion. This 7-day request for an enlargement is necessitated by the fact that, principal counsel for the Government was on annual leave during the week of August 25-29, 2008. Additionally, counsel for the agency was in training and unavailable during the same time period and the Department of Justice reviewer in this case is on leave from August 29-September 5, 2008. The additional time requested is necessary to allow Government counsel to complete draft responses to the plaintiffs' partial motion for summary judgment and proposed findings of uncontroverted fact and submit the responses for review before filing. For these reasons, defendant respectfully requests that the Court grant defendant an enlargement of time of 7 days, to and including September 9, 2008, within which to respond to

Case 1:07-cv-00790-ECH

Document 16

Filed 09/02/2008

Page 2 of 2

plaintiffs' partial motion for summary judgment and accompanying proposed findings of uncontroverted fact. Respectfully submitted, GREGORY G. KATSAS Assistant Attorney General JEANNE E. DAVIDSON Director

/s/ Todd M. Hughes by Martin F. Hockey, Jr. TODD M. HUGHES Deputy Director

OF COUNSEL: Michael J. Dierberg William P. Rayel Trial Attorneys Commercial Litigation Branch Civil Division Department of Justice

/s/ Shalom Brilliant SHALOM BRILLIANT Senior Trial Counsel Commercial Litigation Branch Civil Division Department of Justice 1100 L Street, N.W. Attn: Classification Unit 8th Floor Washington, D.C. 20530 Tele: (202)616-8275 Fax: (202) 305-7643 Attorneys for Defendant

September 2, 2008

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