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

Case 1:07-cv-00166-CCM

Document 9

Filed 07/20/2007

Page 1 of 1

IN THE UNITED STATES COURT OF FEDERAL CLAIMS PAUL E. DOLAN Plaintiff, v. ) ) ) ) ) ) ) ) ) ) )

Civil Action No. 07-166C (C.O.C.Miller)

THE UNITED STATES Defendant,

PLAINTIFF'S CONSENT MOTION FOR ENLARGEMENT OF TIME TO RESPOND TO DEFENDANT'S MOTIONS TO DISMISS OR IN THE ALTERNATIVE TO STAY PROCEEDINGS Plaintiff-Dolan moves, with consent of defendant, for an extension of 14 days to August 3, 2007, to jointly respond to defendant's motions to dismiss or for remand. This is Dolan's second extension request, the court granting the first for 9 days to respond jointly by July 20, 2007. Extraordinary cause exists to grant this motion. Last week, counsel was injured in an accident during an overnight camping trip. He underwent surgery to his right hand and arm, involving multiple sutures, tetanus and morphine shots, antibiotics, etc. Followup treatment was 20 July (Conifer Mountain Family Medicine, Colorado). Absent any complications, counsel is expected to have full use of his hand and arm soon to complete legal briefs by August 3, 2007. WHEREFORE, Dolan respectfully requests that the Court grant an enlargement of time of 14 days, up to and including August 3, 2007, to submit his joint response. July 20, 2007 Respectfully submitted,

a/s John A. Wickham Counsel for Plaintiff-Dolan 32975 Saint Moritz Drive Evergreen CO 80439 303 670-3825