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

Case 1:07-cv-00248-LJB

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS ________________________________________________ ) ) ) Plaintiff, ) ) v. ) ) THE UNITED STATES OF AMERICA, ) ) Defendant. ) ________________________________________________) MELISSA ADDE,

Case No. 07-248C Judge Bush

CONSENT MOTION FOR EXTENSION OF TIME Plaintiff Melissa Adde respectfully moves for an extension of time to submit her Sur-SurReply in the above matter: 1. to Dismiss. 2. Plaintiff's Sur Sur-Reply in Opposition of Defendant's Motion to Dismiss is due On January 11, 2008, Defendant filed with this Court its Sur-Reply of its Motion

to be filed on or before January 25, 2008. 5. Due to his conflicting work schedule and out of office work travel, counsel for

Plaintiff respectfully requests an extension of time of ten (10) days to submit and serve Plaintiff's Sur Sur-Reply, extending Plaintiff's filing deadline to February 4, 2008. 6. On January 23, 2008, counsel for Plaintiff contacted counsel for Defendant

request consent for the present motion. 7. On January 24, 2008, counsel for Defendant consented to counsel for Plaintiff's

Motion for Extension of Time by 10 days.

Case 1:07-cv-00248-LJB

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7.

Thus, Plaintiff requests this motion for extension of time to file her Sur Sur-Reply

by ten (10) days, until February 4, 2008, be granted by this Honorable Court. Respectfully Submitted,

Melissa Adde By Counsel

_____/s/__________________________ R. Scott Oswald, Esq. Nicholas Woodfield, Esq. The Employment Law Group, P.C. 888 17th St. NW, Suite 900 Washington, D.C. 20006 (202)261-2806 (202)261-2835(facsimile) Counsel for Petitioner

CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing Consent Motion for Extension of Time was served by electronic mail and by first-class mail, postage prepaid, this 24th day of January, 2008 on the following counsel of record: Maame A.F. Ewusi-Mensah, Esq. Trial Attorney Commercial Litigation Branch Civil Division United States Department of Justice 1100 L Street, NW Attn: Classification Unit 8th Floor Washington, D.C. 20530 Phone: (202) 353-0503 Fax: (202) 514-8624 [email protected]

_/s/ Nicholas Woodfield_________________ Nicholas Woodfield, Esq.

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Case 1:07-cv-00248-LJB

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS ________________________________________________ ) ) ) Plaintiff, ) ) v. ) ) THE UNITED STATES OF AMERICA, ) ) Defendant. ) ________________________________________________) MELISSA ADDE,

Case No. 07-248C Judge Bush

[PROPOSED] ORDER GRANTING CONSENT MOTION FOR EXTENSION OF TIME Upon consideration of Plaintiff's Consent Motion for Extension of Time, it is by the Court this ___ day of January, 2008, ORDERED 1. That Plaintiff's Consent Motion for Extension of Time is hereby GRANTED; and 2. That Plaintiff's Sur Sur-Reply in Opposition of Defendant's Motion to Dismiss is due to be filed on or before February 4, 2008.

_______________________________ Honorable Judge Bush

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Case 1:07-cv-00248-LJB

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Copies to: R. Scott Oswald, Esq. Nicholas W. Woodfield, Esq. The Employment Law Group, PC 888 17th Street, NW, Suite 900 Washington, DC 20006 (202) 261-2826 (202) 261-2835 (facsimile) [email protected] [email protected] Maame A.F. Ewusi-Mensah, Esq. Trial Attorney Commercial Litigation Branch Civil Division United States Department of Justice 1100 L Street, NW Attn: Classification Unit 8th Floor Washington, D.C. 20530 Phone: (202) 353-0503 Fax: (202) 514-8624 [email protected]

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