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

Case 1:06-cv-00442-TCW

Document 29

Filed 08/16/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS __________________________________________ ) ) ) ) ) ) ) ) Plaintiffs, ) ) v. ) ) THE UNITED STATES OF AMERICA, ) ) Defendant. ) __________________________________________) REV. FR. PRISCO E. ENTINES, JUSTINA CORCELLES HERNANDEZ, FRANCISCO GUTIEREZ FERRER, JULIETA TABOADA ABELLA, MARIA LAPAY LAURENCIANO, and WENCESLAO N. RODRIGUEZ,

Nos.

06-193C, 06-191C, 06-205C, 06-434C, 06-442C, 06-449C Judge Wheeler

PLAINTIFFS' UNOPPOSED MOTION, OUT OF TIME, FOR AN ENLARGEMENT OF TIME TO RESPOND TO THE MOTION TO DISMISS Plaintiffs respectfully request the Court's leave to file, out of time, this request for an enlargement of time. On June 14, 2007, the United States filed a motion to dismiss the complaints in the six above-captioned cases. On July 31, 2007, Plaintiffs' counsel filed a motion to withdraw, citing "fundamental and irreconcilable disagreements" regarding the response to the motion to dismiss. Plaintiffs' response to the government's motion to dismiss was due on August 15, 2007. Plaintiffs respectfully request an extension of time pending the Court's resolution of the motion to withdraw. Further, should that motion be granted, Plaintiffs will require additional time to prepare their responses to the government's motion to dismiss. On August 16, 2007, counsel for the Department of Justice, Kenneth Kessler, advised the undersigned that the government does not oppose the motion.

Case 1:06-cv-00442-TCW

Document 29

Filed 08/16/2007

Page 2 of 2

Respectfully submitted,

/s/ Richard W. Arnholt _ Richard W. Arnholt JENNER & BLOCK LLP 601 Thirteenth Street, N.W. Washington, D.C. 20005 Tel: (202) 639-6025 Fax: (202) 661-4829 Counsel of Record for Plaintiffs Dated: August 16, 2007 Of Counsel: David A. Churchill JENNER & BLOCK LLP

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