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

Case 1:07-cv-00206-FMA

Document 24

Filed 10/24/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS Lublin Corp., t/a Century 21 Advantage Gold, Plaintiff, v. The United States, Defendant. ) ) ) ) ) ) ) ) )

No. 07-206C (Judge Allegra)

DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME

Defendant respectfully requests this Court to grant defendant an enlargement of time of 11 days, to and including November 13, 2007, within which to file its reply brief in support of its motion to dismiss or, in the alternative, for summary judgment. This is defendant's first request for an enlargement of time for this purpose. Defendant's reply brief currently is due November 2, 2007. Plaintiff does not oppose the instant motion. Additional time is necessary because undersigned counsel of record was, or will be, out of the office for depositions, in another case before this Court, on the following dates: October 23, 2007, and October 29-31, 2007. Moreover, defendant requires the remainder of this week to prepare for the complex 30(b)(6) deposition to be held on October 30-31, 2007 in Pittsburgh, PA. Accordingly, we respectfully request that the Court grant an 11 day enlargement of time within which the Government may file its reply brief.

Respectfully submitted, PETER D. KEISLER Assistant Attorney General

Case 1:07-cv-00206-FMA

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Filed 10/24/2007

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JEANNE E. DAVIDSON Director

s/ Mark A. Melnick MARK A. MELNICK Assistant Director

s/ Matthew H. Solomson MATTHEW H. SOLOMSON Trial Attorney, Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit, 8th Floor 1100 L Street, N.W. Washington, D.C. 20530 Tel: (202) 305-3274 Fax: (202) 514-8624 October 24, 2007 Attorneys for Defendant

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Case 1:07-cv-00206-FMA

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Filed 10/24/2007

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CERTIFICATE OF SERVICE

I hereby certify that, on this 24th day of October 2007, I caused to be filed electronically the foregoing DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME with the United States Court of Federal Claims. 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/ Matthew H. Solomson MATTHEW H. SOLOMSON