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

Case 1:07-cv-00004-TCW

Document 34

Filed 07/31/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS LAUDES CORPORATION, Plaintiff, v. ) ) ) ) No. 07-4C ) ) (Judge Wheeler) ) ) ) )

THE UNITED STATES, Defendant.

DEFENDANT'S UNOPPOSED MOTION FOR EXTENSION OF TIME Pursuant to Rule 6(b) of the Rules of the United States Court of Federal Claims, we respectfully request that the Court enlarge the deadline for the Government to file its reply to plaintiff's opposition to "Defendant's Motion For Partial Dismissal Or, In The Alternative, For Partial Summary Judgment" by two weeks, from August 7, 2008, to August 21, 2008. This is our first request for an enlargement for this matter. We have discussed this matter with counsel for the plaintiff, and he has indicated that plaintiff will not oppose this motion. The additional time is requested because counsel for the Government will be in the midst of a ten-day vacation when the reply brief is due. This vacation will prevent him from formulating and filing an adequate response to plaintiff's extensive opposition to our pending motion. Accordingly, we respectfully request that the Court grant this unopposed motion for extension and enlarge the deadline for the Government to file its reply brief until August 21, 2008.

Case 1:07-cv-00004-TCW

Document 34

Filed 07/31/2008

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Respectfully submitted, GREGORY G. KATSAS Assistant Attorney General JEANNE E. DAVIDSON Director

s/Franklin E. White, Jr. FRANKLIN E. WHITE, JR. Assistant Director

s/J. Reid Prouty J. REID PROUTY Trial Attorney Commercial Litigation Branch Civil Division Department of Justice 1100 L Street, N.W. Attn: Classification Unit 8th Floor Washington, D.C. 20530 Tele: (202) 305­7586 Fax: (202) 514-7969 Attorneys for Defendant July 31, 2008

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