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

Case 1:02-cv-00796-FMA

Document 37

Filed 06/15/2004

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS INFORMATION SYSTEMS & NETWORKS CORPORATION, Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) )

No. 02-796C (Judge Allegra)

DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME Defendant respectfully requests the Court to grant an enlargement of time of seven days, to and including June 28, 2004. to file its reply in support of the Government's cross-motion for summary judgment. The reply is currently due on June 21, 2004. Counsel for plaintiff has informed counsel for the defendant that he does not oppose this request for an enlargement of time. No previous enlargements of time for this purpose have been requested or granted. The undersigned counsel for the Government was assigned responsibility for this case on May 27, 2004. Since assuming responsibility for this case, the undersigned counsel was required to file on June 4, 2004, a motion to dismiss in Deeks v. United States, No. 04-580C (Fed. Cl.), to meet with witnesses for depositions in June 2004 in Medgar Evers v. United States, No. 96-809C (Fed. Cl.), and to travel to Columbia, South Carolina and to Garden City, New York for depositions in Spodek v. United States, No. 03-1444C (Fed. Cl.). In addition, the undersigned counsel is required to file on June 18, 2004, a reply in support of its motion to dismiss in Carter v. United States, No. 04-284C

Case 1:02-cv-00796-FMA

Document 37

Filed 06/15/2004

Page 2 of 2

(Fed. Cl.), on June 16, 2004, a brief in DeLoach v. Department of Transportation, No. 043161 (Fed. Cir.), and on June 24, 2004, a brief in Cheers v. OPM, No. 04-3217 (Fed. Cir.). Accordingly, the Government requests that it be allowed an additional seven days to file its brief in order to fully consider and address the issues presented by the parties' cross-motions for summary judgment and to consult with agency counsel. For the foregoing reasons, defendant respectfully requests the Court to grant an enlargement of time of seven days, to and including June 28, 2004, to file its reply in support of the Government's cross-motion for summary judgment. Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director s/ Brian M. Siskin/ by Mark A. Melnick BRIAN M. SIMKIN Assistant Director s/ Doris S. Finnerman DORIS S. FINNERMAN Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L Street, N.W. Washington, D.C. 20005 Phone:(202) 307-0300 Fax: (202) 305-7643 Attorneys for Defendant 2