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

Case 1:06-cv-00448-GWM

Document 10

Filed 08/28/2006

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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 MOTION FOR ENLARGEMENT OF TIME Plaintiff respectfully requests an enlargement of time of thirty (30) calendar days, to and including October 18, 2006, to respond or otherwise plead to defendant's motion to dismiss pursuant to Rule 12(b)(1) filed with the Court on August 8, 2006. This is plaintiff's first request for an enlargement of time for this matter. Undersigned counsel unsuccessfully attempted to contact counsel for defendant to discuss this motion, as she is out of the office until September 4, 2006. The reason for this request is that undersigned counsel, who is assisting with the response, will be out of the office in Texarkana, Texas the week of August 28, 2006 for depositions in another matter. The following week is a short holiday week, during which undersigned counsel and counsel of record, Joseph A. Camardo, Jr., will be in Long Island, New York on another client matter. The following week (September 11, 2006), undersigned counsel must be in Worcester, Massachusetts for a Court hearing on another client matter. In addition, Joseph A. Camardo, Jr., counsel of record, will be in Detroit for most of this week for hearings on another client matter. 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 1

Case 1:06-cv-00448-GWM

Document 10

Filed 08/28/2006

Page 2 of 3

plead to defendant's motion to dismiss thirty (30) days from September 18, 2006 to October 18, 2006. Dated: August 28, 2005 s/ Kevin M. Cox Joseph A. Camardo, Jr. By: Kevin M. Cox 127 Genesee Street 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

Document 10

Filed 08/28/2006

Page 3 of 3

CERTIFICATE OF SERVICE I certify under penalty of perjury that on August 28, 2005, 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/ Kevin M. Cox Kevin M. Cox

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