Free Motion for Extension of Time - District Court of Federal Claims - federal

Case 1:06-cv-00334-LJB

Document 17

Filed 04/30/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS ____________________________________ ) DOUGLAS S. JOHNSON ) ) Plaintiff, ) ) v. ) ) UNITED STATES OF AMERICA, ) ) Defendant. ) ____________________________________)

Case No. 06-334C (Judge Lynn J. Bush)

UNOPPOSED MOTION FOR ENLARGEMENT OF TIME Pursuant to Rule 6(b) of the Rules of the United States Court of Federal, plaintiff respectfully request a 60-day enlargement of time, to and including June 29, 2007, within which the parties may file their dispositive motions. The parties' dispositive motions are due on April 30, 2007. This is plaintiff's first request for enlargement of time for this purpose. Counsel for defendant has indicated that defendant is not opposed to this motion. Plaintiff's counsel requests this enlargement because the claims of similarly situated plaintiffs in Boyer v. United States, No. 00-641C have been settled and additional time is needed to prepare a settlement proposal for Mr. Johnson's claims. As stated in the parties' joint preliminary status report, Mr. Johnson has been employed by the same Federal agencies as plaintiffs in Boyer, served in the same position as some of the plaintiffs in Boyer (Senior Marine Enforcement Officer), and he asserts claims similar, if not identical, to the claims asserted in Boyer. Because the claims in Boyer have been settled, the parties do not anticipate the need to file summary judgment motions in this case. Therefore, we respectfully request that the Court grant an enlargement of time of 60 days within which the parties may file motions for summary

Case 1:06-cv-00334-LJB

Document 17

Filed 04/30/2007

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judgment, through and including June 29, 2007. Respectfully submitted,

OF COUNSEL: Linda Lipsett Edgar James James & Hoffman 1101 17th Street, N.W. Suite 510 Washington, D.C. 20036 (202) 496-0500

s/Jules Bernstein Jules Bernstein (Counsel of Record) Bernstein & Lipsett, P.C. 1920 L Street, N.W. Suite 303 Washington, D.C. 20036 (202) 296-1798

Attorneys for Plaintiffs Dated: April 30, 2007

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Case 1:06-cv-00334-LJB

Document 17

Filed 04/30/2007

Page 3 of 3

CERTIFICATE OF FILING I hereby certify under penalty of perjury that on this 30th day of April 2007, a copy of the foregoing "MOTION FOR ENLARGEMENT OF TIME" 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/Jules Bernstein