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

Case 1:07-cv-00145-TCW

Document 16

Filed 12/21/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS

STOUT ROAD ASSOCIATES, INC. t/a HILTON PHILADELPHIA CITY AVENUE, Plaintiff, v. THE UNITED STATES, Defendant.

) ) ) ) ) No. 07-145C ) (Judge Wheeler) ) ) ) )

DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Pursuant to Rules 6(b) and 6.1 of the Rules of the United States Court of Federal Claims ("RCFC"), defendant, the United States, respectfully requests an 7-day enlargement of time, to and including January 8, 2007, to file its reply brief in support of its motion for summary judgment. Our reply is currently due on December 31, 2007. This is defendant's second request for an enlargement of time for this purpose, the Court having granted defendant's motion for a thirteen-day enlargement on December 6, 2007. Defendant's counsel has spoken with plaintiff's counsel about this enlargement of time, who stated that he does not oppose this enlargement. The enlargement is requested because of counsel of record's current workload, which includes drafting discovery responses in Lakeland Partners LLC v. United States, Court of Federal Claims No. 2006-295, due December 31, 2007 and Ann Thomas v. United States, Court of Federal Claims No. 2007-212, due December 28, 2007; and responding to a motion to compel in Lakeland Partners LLC v. United States, Court of Federal Claims No. 2006-295, due January 7, 2008. For the foregoing reasons, defendant respectfully requests that the Court grant its motion for an enlargement of time of 7 days, to and including January 8, 2008 within which to file a

Case 1:07-cv-00145-TCW

Document 16

Filed 12/21/2007

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response to the plaintiff's complaint. Respectfully submitted,

JEFFREY S. BUCHOLTZ Acting Assistant Attorney General JEANNE E. DAVIDSON Director /s/Mark A. Melnick____ MARK A. MELNICK Assistant Director /s/Carrie A. Dunsmore________ CARRIE A. DUNSMORE Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 1100 L Street, N.W., 8th Floor Washington, D.C. 20530 Tel: (202) 305-7576 Fax: (202) 514-8624 December 21, 2007 Attorneys for Defendant

Case 1:07-cv-00145-TCW

Document 16

Filed 12/21/2007

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Certificate of Filing I hereby certify that on this 21th day of December, 2007, a copy of the Defendant's Unopposed Motion For An Enlargement Of Time 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/Carrie A. Dunsmore Carrie A. Dunsmore