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

Case 1:07-cv-00003-MMS

Document 26

Filed 06/23/2008

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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)

PLAINTIFF'S 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 enlargement of time of thirty (30) days within which to file her Dispositive Motion herein. In support of this motion plaintiff shows the Court the following: 1. Plaintiff's Dispositive Motion is presently due to be filed on July 1, 2008. Plaintiff's

requested extension would bring the date for filing plaintiff's dispositive motion to July 31, 2008. This is plaintiff's first request for an enlargement of time for this purpose. Undersigned counsel has communicated with Shalom Brilliant, counsel for defendant on June 23, 2008, and Mr. Brilliant stated that defendant does not oppose the granting of this motion. 2. The basis for this request is that counsel for the parties are seeking to determine a

mutually convenient date in July, 2008, for plaintiff's counsel to conduct a deposition of defendant under RCFC 30(b)(6), and the parties have not yet agreed upon such date. The granting of this motion will permit the taking of the aforementioned deposition and the timely preparation and filing of plaintiff's Dispositive Motion by July 31, 2008.

Case 1:07-cv-00003-MMS

Document 26

Filed 06/23/2008

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For the foregoing reasons, it is respectfully requested that the Court grant the instant motion for a thirty (30) day enlargement of time until July 31, 2008, for the filing of plaintiff's Dispositive Motion. 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 Plaintiff Dated: June 23, 2008

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Case 1:07-cv-00003-MMS

Document 26

Filed 06/23/2008

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CERTIFICATE OF FILING I hereby certify under penalty of perjury that on this 23rd day of June 2008, a copy of the foregoing "PLAINTIFF'S UNOPPOSED 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