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

Case 1:07-cv-00134-SGB

Document 17

Filed 06/17/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS ALIAMANU CONSERVATION PARTNERS, INC, Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) )

No. 07-134C (Judge Braden)

DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Defendant respectfully requests an enlargement of time of 30 days, to and including August 6, 2008, within which to file its response to plaintiff's June 4, 2008 motion for summary judgment on the Government counterclaim that is currently due on July 7, 2008. This is defendant's first request for an enlargement of time for this purpose. Defendant has contacted plaintiff's counsel who has indicated that plaintiff does not oppose this request. The reason for this request is that Department of Justice counsel was out of the office until June 16, 2008, performing reserve military duty. Thereafter, he will be out again on June 19 and 20, 2008, on leave and from June 24 until July 7, 2008, for the purpose of taking depositions in Tampa, Florida in the case of Great Lakes v. United States, No. 07-218C (Fed. Cl.), and case-related travel to Germany in the matter of Securitas v. United States, No. 07-255C (Fed. Cl.). Department of Justice counsel will be back in the office on July 7 and has to respond to the summary judgment motions both in this case and in the case of Southeast Restoration, Inc., v. United States, No. 07-884C (Fed. Cl.). Department of Justice counsel respectfully requests the 30-day enlargement in order to devote the necessary time and resources to respond to plaintiff's motion.

Case 1:07-cv-00134-SGB

Document 17

Filed 06/17/2008

Page 2 of 3

For these reasons, defendant respectfully requests that the Court grant its unopposed motion for a 30-day enlargement of time within which to file its response to plaintiff's summary judgment motion. Respectfully submitted, GREGORY G. KATSAS Acting Assistant Attorney General JEANNE E. DAVIDSON Director s/Steven J. Gillingham STEVEN J. GILLINGHAM Assistant Director s/Armando Rodriguez-Feo ARMANDO A. RODRIGUEZ-FEO Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit, 8th Floor 1100 L St., NW Washington, D.C. 20530 Tele: (202) 307-3390 Fax: (202) 514-8624 June 18, 2008 Attorneys for Defendant

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Case 1:07-cv-00134-SGB

Document 17

Filed 06/17/2008

Page 3 of 3

CERTIFICATE OF FILING I hereby certify that on this 18th day of June, 2008, a copy of the foregoing "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. The parties may access this filing through the Court's system.

s/Armando Rodriguez-Feo