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

Case 1:07-cv-00756-CCM

Document 9

Filed 04/21/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS SUSAN L. McCARRON ) ) ) ) ) ) ) ) ) ) ) ) NO.: 07-CV-756 (Judge Miller)

Plaintiffs, V. UNITED STATES DEPARTMENT OF THE ARMY and DEFENSE FINANCE AND ACCOUNTING SERVICE, Defendant.

PLAINTIFF'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Pursuant to Rule 6(b) of the Rules of the United States Court of Federal Claims ("RCFC"), plaintiff respectfully requests an enlargement of time of 14 days to, and including May 9, 2008 within which to file plaintiff's reply to defendants' motion to dismiss or, in the alternative, for summary judgment. Plaintiff's reply is currently due to be filed on or before April 25, 2008. This is plaintiff's second request for an enlargement of time for this purpose. Prior to filing this motion, plaintiff's counsel contacted defendants' counsel who advised that defendant did NOT object to the granting of this motion. We presently anticipate that the 14 additional days are reasonable and required for the plaintiff to file her opposition papers. Time is necessary for plaintiff's counsel to complete drafting and to file plaintiff's opposition to defendants' motion to dismiss. Further, a 14 day enlargement of time will not significantly impact the total period of time for the Court to reach a decision in this case and plaintiff's counsel does not anticipate seeking any further enlargements of time to file plaintiff's opposition to defendants' motion to dismiss. Plaintiff's counsel is General Counsel to the Federal Law Enforcement Officers' Association. In such capacity, plaintiff's counsel is actually engaged and out of the office for the next 5 to 7 business days on various personnel matters. Specifically, plaintiff's counsel is currently in Philadelphia, Pennsylvania representing a federal agent who was involved in a shooting over the weekend. From Pennsylvania, your plaintiff's counsel is traveling to

Case 1:07-cv-00756-CCM

Document 9

Filed 04/21/2008

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Bloomington, Indiana to Chicago, Illinois and then to Harrisburg Pennsylvania before coming back to his office. Consequently, plaintiffs' counsel, despite his best efforts, is unable to file plaintiff's opposition to the defendants' motion to dismiss on or before April 25, 2008.

Taking into consideration all of the matters recited above, plaintiff respectfully request that the Court grant this motion for an enlargement of time to, and including, May 9, 2008.

April 21, 2008 Glen Cove, NY

Respectfully submitted,

Lawrence Berger Attorney for Plaintiffs Mahon & Berger, Esqs. 21 Glen Street, Suite D Glen Cove, NY 11542

Case 1:07-cv-00756-CCM

Document 9

Filed 04/21/2008

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