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

Case 1:07-cv-00250-CCM

Document 7

Filed 06/28/2007

Page 1 of 3

IN THE UNITED STATES COURT OF FEDERAL CLAIMS

PAUL D. RIPPA, Plaintiff, v. THE UNITED STATES, Defendant

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No. 07-250C (Judge Christine O.C. Miller)

DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Pursuant to Rules 6(b) and 6.1 of the Rules of the United States Court of Federal Claims ("RCFC"), defendant, the United States, respectfully requests an enlargement of time to file a response to the plaintiff's motion for summary judgment, to and including September 4, 2007, which is the same date that defendant's answer is due. Plaintiff's counsel has stated that he does not object to this motion. This is our first request for enlargement for this purpose. The enlargement is requested because defendant represents that it cannot formulate its response to plaintiff's motion for summary judgment until it has formulated its response to plaintiff's complaint. Defendant recently sought and was granted an extension of time to respond to the complaint, until August 9, 2007. Defendant seeks an additional 26 days after filing its response to plaintiff's complaint to formulate its response to plaintiff's motion for summary judgment. Additionally, the enlargement is requested because of counsel of record's current workload, answering complaints in Ann Thomas v. United States, Fed. Cl. No. 07-212C, due on June 29, 2007, and Former Employees of Invista S.A.R.L. v. United States, Court of International Trade No. 2007-0160, due July 16, 2007, and drafting a motion for summary

Case 1:07-cv-00250-CCM

Document 7

Filed 06/28/2007

Page 2 of 3

judgment on the administrative record in Ironclad/EEI v. United States, Fed. Cl. No. 07-280, due on July 23, 2007. For the foregoing reasons, defendant respectfully requests that the Court grant its motion for an enlargement of time, to and including September 4, 2007, within which to file a response to the plaintiff's motion for summary judgment.

Respectfully submitted,

PETER D. KEISLER Assistant Attorney General JEANNE E. DAVIDSON Director

/s/ Mark A. Melnick MARK A. MELNICK Assistant Director /s/ Carrie A. Dunsmore CARRIE A. DUNSMORE Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 1100 L Street, N.W., 8th Floor Washington, D.C. 20530 Tel: (202) 305-7576 Fax: (202) 514-8624 June 28, 2007 Attorneys for Defendant

Case 1:07-cv-00250-CCM

Document 7

Filed 06/28/2007

Page 3 of 3

Certificate of Filing I hereby certify that on this 28th day of June, 2007, a copy of "Defendant's Unopposed 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. Parties may access this filing through the Court's system. /s/Carrie A. Dunsmore Carrie A. Dunsmore