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

Case 1:07-cv-00355-NBF

Document 21

Filed 07/24/2008

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UNITED STATES COURT OF FEDERAL CLAIMS ) ) ) ) ) ) ) ) ) ) ) )

TEXAS NATIONAL BANK f/k/a MERCEDES NATIONAL BANK Plaintiffs, v. UNITED STATES, Defendant

Court No. 07-355C Judge Firestone

DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME Pursuant to Rule 6(b)(1) and 6.1 of the United States Court of Federal Claims (RCFC), defendant, the United States, respectfully requests a five-day enlargement of time, to and including July 30, 2008, to file a motion for summary judgment. Our motion is currently due on July 25, 2008. No previous requests for enlargement of time have been made. On July 23, 2008, counsel for defendant spoke with Edward Snyder, counsel for the plaintiff, who indicated he does not oppose this motion. The additional time is necessary because counsel for the Government was in trial from June 30, 2008 to July 18, 2008. Additionally, counsel for the Government is responsible for filing an opposition to a cross motion for summary judgment in another case that is due on July 29, 2008. This brief enlargement is requested for counsel to prepare a thorough response, and to obtain the necessary supervisory review of the Government's response. For this reason, defendant respectfully requests the Court to grant this motion for enlargement of time of five days, to and including July 30, 2008, within which to file a motion for summary judgment.

Case 1:07-cv-00355-NBF

Document 21

Filed 07/24/2008

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GREGORY G. KATSAS Assistant Attorney General JEANNE E. DAVIDSON Director

MARK A. MELNICK Assistant Director

OF COUNSEL: ANDREW JONES Office of Assistant Chief Counsel U.S. Customs and Border Protection 6650 Telecom Drive Indianapolis, Indiana 46278 s/ Joan M. Stentiford JOAN M. STENTIFORD Trial Attorney Commercial Litigation Branch Civil Division Department of Justice 1100 L Street, N.W. Attn: Classification Unit 8th Floor Department of Justice Phone: (202) 616-0341 Fax: (202) 514-8624 Attorneys for Defendant

July 24, 2007

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Case 1:07-cv-00355-NBF

Document 21

Filed 07/24/2008

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CERTIFICATE OF FILING I hereby certify under penalty of perjury that on this 24th day of August, 2008,"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/ Joan M. Stentiford_____ JOAN M. STENTIFORD