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

Case 1:07-cv-00773-SGB

Document 7

Filed 03/14/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS LOUISE HALL and GLENN GOULD, Plaintiffs, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) )

No. 07-773C (Judge Braden)

DEFENDANT'S SECOND UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Defendant respectfully requests an enlargement of time of 14 days, to and including March 28, 2008, within which to file its response to plaintiff's complaint. due to be filed on March 14, 2008. Defendant's response is now This is defendant's second Defendant

request for an enlargement of time for this purpose.

has contacted counsel for plaintiffs, who has indicated that plaintiffs do not oppose this request. Counsel of record needs additional time to finalize a response to the complaint and coordinate that response internally within the Department of Justice. Counsel of record believed

that he would be able to file defendant's response to the complaint today, but now realizes that additional time is needed. Thus, the enlargement is requested because of counsel of record's workload, which includes a reply to a motion to dismiss in Hines v. United States, No. 07-623C, an opposition to a motion to supplement in Lewis v. United States, No. 07-591c, and briefing before the United States Court of Appeals for the Federal Circuit in Perry v. United States, No. 2008-7026.

Case 1:07-cv-00773-SGB

Document 7

Filed 03/14/2008

Page 2 of 3

For these reasons, defendant respectfully requests that the Court grant its unopposed motion for a 14-day enlargement of time, to and including March 28, 2008, within which to file its response to plaintiff's complaint. Respectfully submitted, JEFFREY S. BUCHOLTZ Acting Assistant Attorney General JEANNE E. DAVIDSON Director

/s Brian M. Simkin BRIAN M. SIMKIN Assistant Director

/s L. Misha Preheim L. MISHA PREHEIM Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L St., NW Washington, D.C. 20530 Tele: (202) 305-3087 Fax: (202) 305-1571 March 14, 2008 Attorneys for Defendant

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Case 1:07-cv-00773-SGB

Document 7

Filed 03/14/2008

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CERTIFICATE OF FILING I hereby certify that on the 14th day of March, 2008, a copy of the foregoing "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. system. Parties may access this filing through the Court's

s/L. Misha Preheim