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

Case 1:06-cv-00381-TCW

Document 16

Filed 02/22/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS TODD CONSTRUCTION CO., INC., Plaintiff, v. THE UNITED STATES OF AMERICA ex rel DEPARTMENT OF THE ARMY, Defendant. ) ) ) ) ) ) ) ) ) )

No. 06-381C (Judge Wheeler)

PLAINTIFF'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME Plaintiff, Todd Construction Co., Inc. ("Todd"), respectfully requests an enlargement of time of 14 days, to and including March 19, 2007, in which to file its response to the motion for summary judgment of defendant, The United States of America ex rel Department of the Army ("USA"). The response is now due on March 5, 2007. Todd's counsel has begun preparing its response but requires more time to complete. In addition, Todd's counsel has been involved in a lengthy, time-consuming referee/mediation process in a case styled, Romar Supply, Inc. v. Bar-S Foods Co., et al.; Bar-S Foods Co. v. Whiting-Turner Contracting Company, et al.; The Reynolds Co. v. Bar-S Foods Co., et al., In the District Court of Jackson County, Oklahoma, Consolidated Case No. CJ-2005-290. Todd's counsel also has to be out of the office for personal reasons during the week of February 26, 2007. For these reasons, Todd respectfully requests that the Court grant its motion for a 14-day enlargement of time within which to file its response to USA's motion for summary judgment. Todd's counsel is authorized to state that USA's counsel is not opposed to this motion.

Case 1:06-cv-00381-TCW

Document 16

Filed 02/22/2007

Page 2 of 2

Dated February 22, 2007.

s/Robert L. Magrini Robert L. Magrini, OBA #12385 Hayes Magrini & Gatewood 1220 North Walker (73103) Post Office Box 60140 Oklahoma City, Oklahoma 73146-0140 [email protected] Phone: (405) 235-9922 Fax: (405) 235-6611 Attorneys for Plaintiff, Todd Construction Co., Inc. CERTIFICATE OF FILING On the 22nd day of February, 2007, I electronically transmitted the foregoing "Plaintiff's Unopposed Motion for Enlargement of Time" to the Clerk of Court using the ECF System for filing and transmittal of a Notice of Electronic Filing to the following ECF registrants: Sean B. McNamara. I understand that notice of this filing will be sent to all parties by operation of the Court's electronic filing system. The parties may access this filing through the Court's system.

s/Robert L. Magrini Robert L. Magrini

todd.gen\motion to extend time

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