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

Case 1:06-cv-00446-MCW

Document 14

Filed 03/15/2007

Page 1 of 3

IN THE UNITED STATES COURT OF FEDERAL CLAIMS

LEROY D. POPE, Plaintiff, v. THE UNITED STATES, Defendant.

) ) ) ) ) ) ) ) ) ) )

No. 06-446C (Judge Williams)

PLAINTIFF'S SECOND MOTION FOR AN ENLARGEMENT OF TIME FOR RESPONDING TO DEFENDANT'S MOTION TO DISMISS Pursuant to Rule 6(b) of the Rules of the Court of Federal Claims, the Plaintiff respectfully requests that the Court enlarge the deadline for responding to the complaint in this case by sixty days, so that the response will be due on Tuesday, May 22, 2007. The current due date is March 22, 2007. This is Plaintiff's second request for an enlargement. The Plaintiff requests this extension for the following reason: Defendant's entire VA department is under investigation. Plaintiff believes that Defendant's head of the VA, is likely to step down in the next week. The Senate and the House of Representatives are in the process of investigation the deficiencies of the VA, many of which are articulated in this case. Plaintiff believes by this extra time being granted, the allegations of Plaintiff will be established fact via the forced resignations in the VA, investigation by the Senate and the House of the VA, thereby allowing Plaintiff's case to proceed less challenged as currently is the case. Granting this enlargement will prejudice neither party. Accordingly, Plaintiff, respectfully request that the Court enlarge the time for responding to the complaint by sixty days- to May 22, 2007. Respectfully submitted, 3/14/06 s/Jeffrey D. Moffatt

Case 1:06-cv-00446-MCW

Document 14

Filed 03/15/2007

Page 2 of 3

Attorney for Plaintiff Law Office of Jeffrey D. Moffatt 43625 N Sierra Hwy, Suite A. Lancaster, CA 93534 Tel: 661 9456121 Fax: 661 9453019 [email protected]

Case 1:06-cv-00446-MCW

Document 14

Filed 03/15/2007

Page 3 of 3

CERTIFICATE OF FILING

I hereby certify that on March 14, 2007, a copy of the foregoing " Plaintiff's Second Motion For An Enlargement of Time For Responding to Defendant's Motion To Dismiss" 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.