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

Case 1:07-cv-00160-EGB

Document 23

Filed 07/11/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS J.O.A. CONSTRUCTION CO., INC., Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 07-160C (Judge Bruggink)

UNOPPOSED MOTION FOR EXTENSION OF TIME WITHIN WHICH TO REPLY TO PLAINTIFF'S RESPONSE TO DEFENDANT'S MOTION TO DISMISS, IN PART Defendant respectfully requests an enlargement of time of 30 days, to and including August 27, 2008, within which to file its reply to plaintiff's response to our motion to dismiss, in part, which is currently due on July 28, 2008. This is defendant's first request for an enlargement of time for this purpose. Plaintiff's counsel does not oppose our request. The reason for this request is that defendant's counsel of record will be out of the office from July 19 through July 26, 2008, in connection with the case of Great Lakes v. United States, No. 07-218C (Fed. Cl.) (a hearing is set in West Palm Beach, Florida for July 21, 2008) and four days vacation. He will be out of the office again from August 9 through 16, 2008, in connection with the taking and defending of depositions in the case of Aliamanu Conservation Partners, Inc., v.

Case 1:07-cv-00160-EGB

Document 23

Filed 07/11/2008

Page 2 of 3

United States, No. 07-134C (Fed. Cl.). Accordingly, Defendant requests a 30-day enlargement of time within which to reply to plaintiff's response to our motion to dismiss, in part. Respectfully, GREGORY G. KATSAS Assistant Attorney General JEANNE E. DAVIDSON Director s/Martin F. Hockey, Jr. MARTIN F. HOCKEY, JR. Assistant Director s/Armando A. Rodriguez-Feo ARMANDO A. RODRIGUEZ-FEO 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) 307-3390 Fax: (202) 514-8624 Attorneys for Defendant

OF COUNSEL:

J. Mackey Ives Litigation Attorney General Litigation Branch Army Litigation Center 901 N. Stuart Street, Ste. 400 Arlington, VA 22203

July 11, 2008

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Case 1:07-cv-00160-EGB

Document 23

Filed 07/11/2008

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CERTIFICATE OF FILING I hereby certify that on this 11th day of April, 2008, a copy of the foregoing "UNOPPOSED MOTION FOR EXTENSION OF TIME WITHIN WHICH TO REPLY TO PLAINTIFF'S RESPONSE TO DEFENDANT'S MOTION TO DISMISS, IN PART" was filed electronically. 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/Armando Rodriguez-Feo