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

Case 1:06-cv-00417-SGB

Document 17

Filed 12/15/2006

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS ____________________________________ ) FRANK FONT ) ) Plaintiff, ) ) v. ) Docket No. 06-417 (SGB) ) THE UNITED STATES OF ) Judge Susan G. Braden AMERICA, ) ) Defendant. ) ____________________________________) PLAINTIFF'S SECOND UNOPPOSED MOTION FOR ENLARGEMENT OF TIME TO FILE ITS RESPONSE TO DEFENDANT'S MOTION TO DISMISS THE COMPLAINT Pursuant to RCFC 6(b), Plaintiff respectfully moves the Court for a seven-day enlargement of time, from December 20, 2006 to and including December 27, 2006, in which to file its response to Defendant's Motion to Dismiss the Complaint. This is the second unopposed request for enlargement of time by Plaintiff. The first request, for a ninety day enlargement, was filed September 22, 2006 and granted by the Court on September 25, 2006. Plaintiff's counsel has diligently analyzed Plaintiff's case and has communicated recommendations to Plaintiff. To further discuss those recommendations, Plaintiff's counsel will be traveling from Washington, D.C. to Coral Gables, Florida to confer with Plaintiff in person on December 19, 2006. Counsel does not believe that any further enlargements will be required.

Case 1:06-cv-00417-SGB

Document 17

Filed 12/15/2006

Page 2 of 2

Defendant's attorney has stated that he has no objection to the allowance of this motion. Accordingly, Plaintiff requests that the Court allow the requested enlargement of time.

Respectfully submitted,

/s/ George M. Clarke III George M. Clarke III Attorney of Record for Plaintiff Baker & McKenzie LLP 815 Connecticut Avenue, N.W. Washington, DC 20006 (202) 452-7000 (202) 452-7074 Dated: December 15, 2006

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