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

Case 1:06-cv-00345-EGB

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Filed 07/09/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS

CASE NO.: 06-345-C JUDGE: ERIC G. BRUGGINK GRACE AND NAEEM UDDIN INC., Plaintiff, v.

THE UNITED STATES, Defendant. __________________________________/ PLAINTIFF'S MOTION FOR EXTENSION OF TIME TO FILE IT'S MEMORANDUM IN RESPONSE TO DEFENDANT'S MOTION TO STAY DISCOVERY Plaintiff, GRACE AND NAEEM UDDIN, INC., (hereinafter

"GNU"), by and through undersigned counsel and pursuant to Rule 7.2(a) of the Rules of the United States Court of Federal Claims hereby files this Motion For Extension of Time to File Its

Memorandum In Response To Defendant's Motion To Stay Discovery states as follows: 1. On or about June 22, 2007 the USDA filed its Motion to Stay Discovery pending its Motion to Dismiss. 2. GNU's Response to the USDA's Motion to Stay Discovery is due on or about Monday, July 9, 2007. 3. Lead counsel for GNU is out of the State and unavailable for review of GNU's Response to USDA's Motion to Stay Discovery 1

Case 1:06-cv-00345-EGB

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and will remain out of the state until on or about July 10, 2007. 4. Counsel for USDA has informed the undersigned that he is

unavailable during the week of July 9, 2007. As a result, he could not be contacted regarding potential consent to the time extension requested in this Motion. 5. Based on the foregoing, GNU requests an extension of four (4) days or until on or about July 13, 2007 in which to respond to USDA's Motion To Stay Discovery. WHEREFORE, the Plaintiff, GRACE AND NAEEM UDDIN, INC., request this Honorable Court to grant an extension of the time in which GNU may file its response to Defendant's Motion to Stay

Discovery and any additional relief this Honorable Court may deem equitable and just. Respectfully submitted, s/ David R. Elder Attorney for Plaintiff DAVID R. ELDER USCFC BAR NO Application Pending FLA. BAR NO. 272442 Elder & Lewis, P.A. Bayview Executive Plaza, Suite 301 3225 Aviation Avenue Coconut Grove, FLA 33133 Tel: (786) 314-5155 Fax: (503) 314-5811

CERTIFICATE OF FILING 2

Case 1:06-cv-00345-EGB

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I hereby certify that on July ____, 2007 a copy of the foregoing "MOTION FOR EXTENSION OF TIME TO FILE RESPONSE TO USDA'S MOTION TO STAY DISCOVERY" was filed electronically. I understand that notice of this filing will be sent to all parties by operation of the Court's electronic filing system. Parties may access this filing through the Court's system. s/ David R. Elder Attorney for Plaintiff DAVID R. ELDER USCFC BAR NO Application Pending FLA. BAR NO. 272442 Elder & Lewis, P.A. Bayview Executive Plaza, Suite 301 3225 Aviation Avenue Coconut Grove, FLA 33133 Tel: (786) 314-5155 Fax: (503) 314-5811

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