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

Case 1:07-cv-00782-RHH

Document 9

Filed 04/17/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS IRA GREEN, INC., Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 07-782C (Senior Judge Hodges)

DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME Pursuant to Rules 6(b)(1) 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 May 2, 2008, within which to file a reply to plaintiff's opposition to defendant's motion to dismiss. The reply is currently due April 18, 2008. This is our first request for an enlargement of time for this purpose. Plaintiff's counsel has represented that plaintiff, Ira Green, Inc., has no objection to this motion. The enlargement is requested because defendant's counsel requires additional time to prepare and receive internal review of the reply, and counsel of record will be out of the office for trial advocacy training at the National Advocacy Center from April 21, 2008, through April 25, 2008. For these reasons, defendant respectfully requests that the Court grant this motion for an enlargement of time by 14 days, to and including May 2, 2008, within which to file a reply to plaintiff's opposition to defendant's motion to dismiss. Respectfully submitted, JEFFREY S. BUCHOLTZ Acting Assistant Attorney General

Case 1:07-cv-00782-RHH

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Filed 04/17/2008

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JEANNE E. DAVIDSON Director s/Patricia M. McCarthy PATRICIA M. McCARTHY Assistant Director s/ Dawn E. Goodman DAWN E. GOODMAN Trial Attorney Commercial Litigation Branch Civil Division U.S. Department of Justice Attn: Classification Unit, 8th Floor 1100 L Street, N.W. Washington, DC 20530 Tel: (202) 616-1067 Fax: (202) 514-8624 April 17, 2008 Attorneys for Defendant

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Case 1:07-cv-00782-RHH

Document 9

Filed 04/17/2008

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CERTIFICATE OF FILING I hereby certify that on this 17th day of April, 2008, a copy of the foregoing "DEFENDANT'S UNOPPOSED MOTION FOR 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/ Dawn E. Goodman DAWN E. GOODMAN