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

Case 1:06-cv-00448-GWM

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Filed 10/05/2006

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

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

PLAINTIFF'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME Plaintiff respectfully requests an enlargement of time of thirty (30) calendar days, to and including November 17, 2006, to respond or otherwise plead to defendant's motion to dismiss pursuant to Rule 12(b)(1). This is plaintiff's second request for an enlargement of time for this matter. Counsel for defendant does not object to the relief requested herein. The reason for this request is that due to a very busy litigation calendar, undersigned counsel will not have sufficient time during the next few weeks to research and respond to defendant's motion. The additional time requested herein should provide counsel with the time needed to adequately respond to defendant's motion and discuss the same with plaintiff. For the foregoing reasons, defendant respectfully requests that the Court grant this motion for an enlargement of time, and extend the time for plaintiff to respond or otherwise plead to defendant's motion to dismiss thirty (30) days from October 18, 2006 to November 17, 2006. Dated: October 5, 2006 s/Joseph A. Camardo, Jr. Joseph A. Camardo, Jr. By: Kevin M. Cox 127 Genesee Street 1

Case 1:06-cv-00448-GWM

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Filed 10/05/2006

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Auburn, New York 10321 Tel: (315) 252-3846 Fax: (315) 252-3508 Attorney for Plaintiff

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Case 1:06-cv-00448-GWM

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Filed 10/05/2006

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CERTIFICATE OF SERVICE I certify under penalty of perjury that on October 5, 2006, I caused to be served by United States Mail (First Class, postage prepaid) of the foregoing, to: Nancy Kim Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor, 1100 L Street Washington, DC 20530

s/Joseph A. Camardo, Jr. Joseph A. Camardo, Jr.

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