Free Motion for Extension of Time - District Court of Federal Claims - federal

Case 1:07-cv-00003-MMS

Document 7

Filed 04/13/2007

Page 1 of 3

IN THE UNITED STATES COURT OF FEDERAL CLAIMS

LINDA A. STOCUM, Plaintiff, v. UNITED STATES OF AMERICA, Defendant.

) ) ) ) ) ) ) ) ) ) )

Case No. 07-03C (Judge Margaret M. Sweeney)

PLAINTIFFS' UNOPPOSED MOTION FOR ENLARGEMENT OF TIME Pursuant to Rule 6(b) of the Rules of the United States Court of Federal Claims ("RCFC"), plaintiff respectfully requests an eight day enlargement of time within which to file the Joint Preliminary Status Report ("JPSR"). The JPSR is currently due on April 30, 2007. The extension would bring the date for filing the JPSR to May 8, 2007. This is plaintiff's first request for an enlargement of time for this purpose. The undersigned counsel spoke with counsel for defendant on April 12, 2007, and counsel indicated that he is not opposed to this motion. The basis for the request is that Plaintiff's counsel, Jules Bernstein and Linda Lipsett, will be out of the country from April 13, 2007 to May 3, 2007, and will be unable to devote adequate time to prepare the JPSR until their return. For the foregoing reason, plaintiff respectfully requests that the Court grant the instant motion for an eight day enlargement of time.

Case 1:07-cv-00003-MMS

Document 7

Filed 04/13/2007

Page 2 of 3

Respectfully submitted,

OF COUNSEL: Linda Lipsett Edgar James James & Hoffman 1101 17th Street, N.W. Suite 510 Washington, D.C. 20036 (202) 496-0500

s/Jules Bernstein Jules Bernstein (Counsel of Record) Bernstein & Lipsett, P.C. 1920 L Street, N.W. Suite 303 Washington, D.C. 20036 (202) 296-1798

Attorneys for Plaintiffs

Dated: April 13, 2007

-2-

Case 1:07-cv-00003-MMS

Document 7

Filed 04/13/2007

Page 3 of 3

CERTIFICATE OF FILING I hereby certify under penalty of perjury that on this 13th day of April 2007, a copy of the foregoing "MOTION FOR 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/Jules Bernstein