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

Case 1:07-cv-00160-EGB

Document 21

Filed 06/27/2008

Page 1 of 1

IN THE UNITED STATES FEDERAL COURT OF CLAIMS J.O.A. CONSTRUCTION CO., INC., A Michigan corporation Plaintiff V THE UNITED STATES. Defendant PLAINTIFF'S MOTION FOR AN ENLARGEMENT OF TIME Plaintiff respectfully requests a second enlargement of time of 30 days, to and including July 11, 2008, within to file its Response to Defendants Motion to Dismiss in Part. The Response was presently due June 12, 2008. This is Plaintiff's second request for an enlargement of time for this purpose. Plaintiff's counsel has contacted Defendant's counsel, who has no objection to the granting of an enlargement of time as requested. This motion is necessary for the Plaintiff's counsel to complete the preparation of its response. Plaintiff's counsel had sought the assistance of another attorney who has the confidence of the Plaintiff's president and has had experience in the practice before this court but has been unable to produce the Response to Defendant's Motion to Dismiss in Part. For these reasons Plaintiff respectfully requests that the Court grant its motion for a 30 day enlargement of time to file its Response to Defendants Motion to Dismiss in Part. June 27, 2008 /s/ John K. Grylls JOHN K. GRYLLS Attorney for Plaintiff 18430 Mack Avenue Grosse Pointe Farms, MI 48236 Tel: (313) 885-0123 Fax: (313) 886-7699 Case Number: 07-160C Senior Judge Brugginlk