Free Response to Motion - District Court of Federal Claims - federal

Case 1:07-cv-00206-FMA

Document 19

Filed 09/21/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS LUBLIN CORPORATION, t/a CENTURY 21 ADVANTAGE GOLD Plaintiff vs. UNITED STATES OF AMERICA Defendant : : : : : : : : : : : No. 07-206C (Judge Allegra)

RESPONSE TO DEFENDANT, UNITED STATES OF AMERICA'S REQUEST FOR ENLARGEMENT OF TIME AND CONSENT MOTION Plaintiff does not oppose defendant's request for an enlargement of time to respond to Plaintiff's first amended complaint. With regard to defendant's request for a Rule 16 Scheduling Order, if the Government intends to move for summary judgment, as stated in its motion, plaintiff respectfully requests that in the Court's Scheduling Order, the Court requires that the Government first file an Answer to plaintiff's first amended complaint and the time for the answer be set prior to the time for the filing of the motion for summary judgment. As indicated in defendant's motion, plaintiff intends to vigorously oppose the Government's motion for summary judgment, and believes that there are numerous issues of fact that would preclude summary judgment at this stage. Respectfully Submitted,

/s/ William F. Thomson, Jr., Esquire WILLIAM F. THOMSON, JR., ESQUIRE

Case 1:07-cv-00206-FMA

Document 19

Filed 09/21/2007

Page 2 of 2

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