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

Case 1:06-cv-00436-MCW

Document 19

Filed 06/04/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS ) ) ) ) ) ) ) ) ) )

ULYSSES INC., Plaintiff, v. UNITED STATES OF AMERICA, Defendant.

06-436C Judge Williams

PLAINTIFF'S MOTION FOR ADDITIONAL TIME TO RESPOND TO THE COURT'S ORDER DATED MAY 22, 2007 DIRECTING RESPONSE TO DEFENDANT'S MOTION FOR LEAVE TO AMEND ANSWER Plaintiff, Ulysses Inc., ("Ulysses"), by its attorneys, Gdanski & Gdanski LLP, respectfully submits the following request for an additional 60 days time to respond to Defendant's Motion for Leave to Amend its Answer. Plaintiff is substituting counsel. Current counsel for Plaintiff will therefore shortly file a motion to withdraw as counsel and there will also be a forthcoming motion to substitute counsel to be filed by Plaintiff's new counsel. Current counsel has spoken to the new counsel, Mr. Kenneth J. Haber, and has received a faxed authorization from the client authorizing the change in counsel as well as new counsel's request for documentation. In addition, new counsel will apply for admission to this Court. This office has informed Mr. Solomson, Esq., counsel for the Defendant, of the proposed change in counsel and Mr. Solomson does not object to the extension of time to respond to the Court's Order directing a response to Defendant's Motion to Amend its Answer, provided that the remainder of the schedule is also moved up by 60 days.

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Case 1:06-cv-00436-MCW

Document 19

Filed 06/04/2007

Page 2 of 3

For the foregoing reasons, Plaintiff requests a 60 day extension of time in which to respond to Defendant's Motion to Amend its Answer.

Date: June 1, 2007

Respectfully submitted, s/ Sam Z. Gdanski SAM Z. GDANSKI Gdanski & Gdanski, LLP. 3 Rockwood Lane Suffern, NY 10901 845-362-4800 Attorney for Plaintiff Ulysses, Inc

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Case 1:06-cv-00436-MCW

Document 19

Filed 06/04/2007

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that on this 4th day of June 2007, a copy of the foregoing Plaintiff's Motion Requesting Additional Time To Respond to the Court's Order Dated May 22, 2007 was filed via electronic filing and notice was sent to all parties.

s/ Sam Z. Gdanski Gdanski & Gdanski, LLP Attorney for Plaintiff 3 Rockwood Lane Suffern, NY 10901

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