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

Case 1:07-cv-00165-JFM

Document 26

Filed 04/16/2008

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS

HERNANDEZ, KROONE AND ASSOCIATES, INC.

) ) ) Plaintiff, ) v. ) ) UNITED STATES OF AMERICA, ) ) Defendant. ) __________________________________________)

NO. 07-165C (Judge Merow)

DEFENDANT'S MOTION FOR AN ENLARGEMENT OF TIME TO FILE REPLY IN SUPPORT OF ITS MOTION TO COMPEL

Defendant, the United States, respectfully requests that this Court grant an enlargement of time of 14 days, to and including May 12, 2008, within which to file a reply brief in support of our pending motion to compel. Plaintiff filed its response to that motion to compel on Monday, April 14, 2008. Defendant's reply currently is due on April 28, 2008. This is defendant's first request for an enlargement of time for this purpose. Undersigned counsel attempted to contact counsel of record for plaintiff to discuss this motion, but was unable to reach him. Our motion for an enlargement of time is necessary because additional time is required for us to review plaintiff's response to our motion to compel, and to draft our reply brief. In that regard, we note that undersigned counsel of record recently was assigned to a bid protest case, CNA Corp. v. United States (Fed. Cl. No. 08-249C), in which opening and responsive briefs are due on April 17, 2008 and April 21, 2008, respectively. A hearing in that case is scheduled for April 22, 2008. In addition, with the exception of that hearing, undersigned counsel of record will be out of the office, with limited computer access, from April 21- 25, 2008.

Case 1:07-cv-00165-JFM

Document 26

Filed 04/16/2008

Page 2 of 2

For the foregoing reasons, defendant respectfully requests that the Court grant its motion for an enlargement of time of 14 days, to and including May 12, 2008, within which defendant may file its reply in support of its motion to compel. Respectfully submitted, JEFFREY S. BUCHOLTZ Acting Assistant Attorney General JEANNE E. DAVIDSON Director s/ Mark A. Melnick by s/ M. Hockey 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 April 16, 2008 Attorneys for Defendant

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