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

Case 1:06-cv-00448-GWM

Document 21

Filed 02/15/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS MICHAEL KAWA, ESQ., Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 06-448C (Judge George W. Miller)

DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME Pursuant to Rule 6(b)(1) of the Rules of the United States Court of Federal Claims ("RCFC"), defendant, the United States, respectfully requests a 21-day enlargement of time, to and including March 12, 2007, within which to file a reply to plaintiff's opposition to defendant's supplemental motion to dismiss. Our reply is currently due on February 19, 2007. This is defendant's first request for enlargement of time for this purpose. Plaintiff's counsel has represented that plaintiff does not oppose the motion. The enlargement is requested because the undersigned counsel for defendant, Nancy M. Kim, needs additional time to draft the Government's reply. Ms. Kim is scheduled to be on vacation from February 15, 2007 to February 19, 2007. In addition, she is required to defend depositions on February 6, 7, and 14, 2007 in Carson v. United States, Fed. Cl. No. 05-612. In addition, she is scheduled to be in San Diego, California, for alternative dispute resolution ("ADR") in Collins National v. United States, Fed. Cl. No. 05-563, from February 28 to March 2, 2007, and is further required to prepare a memorandum for the ADR judge by February 26, 2007. For the foregoing reasons, defendant respectfully requests that the Court grant this motion for an enlargement of time of 21 days, to and including March 12, 2007, within which to file a reply to plaintiff's opposition to defendant's supplemental motion to dismiss.

Case 1:06-cv-00448-GWM

Document 21

Filed 02/15/2007

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Respectfully submitted, PETER D. KEISLER Assistant Attorney General JEANNE E. DAVIDSON Acting Director Franklin E. White, Jr./ Deborah A. Bynum FRANKLIN E. WHITE, JR. Assistant Director Nancy M. Kim/ Lauren S. Moore NANCY M. KIM Trial Attorney Commercial Litigation Branch Civil Division U.S. Department of Justice Attn: Classification Unit, 8th Floor 1100 L Street, N.W. Washington, D.C. 20530 Tel: (202) 353-0546 Fax: (202) 514-8640 Attorneys for Defendant February 15, 2007

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Case 1:06-cv-00448-GWM

Document 21

Filed 02/15/2007

Page 3 of 3

CERTIFICATE OF ELECTRONIC FILING I hereby certify that on February 15, 2007, a copy of the foregoing "DEFENDANT'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/ Lauren S. Moore

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