Case 1:06-cv-00233-BAF
Document 132
Filed 04/14/2008
Page 1 of 2
IN THE UNITED STATES COURT OF FEDERAL CLAIMS FEDERAL AIR MARSHAL 1, ET AL., Plaintiffs, No. 06-233C vs. (Judge Futey) THE UNITED STATES, Defendant.
PLAINTIFFS' CONSENT MOTION FOR AN EXTENSION OF TIME TO FILE A COMBINED REPLY BRIEF IN SUPPORT OF MOTION FOR PARTIAL SUMMARY JUDGMENT AND RESPONSE IN OPPOSITION TO DEFENDANT'S CROSS-MOTION FOR SUMMARY JUDGMENT Plaintiffs, by their counsel, respectfully request that the Court allow them until May 9, 2008, to file their combined reply/response to Defendant's Cross-Motion for Summary Judgment and Opposition to Plaintiffs' Motion for Partial Summary Judgment. In support of this motion, plaintiffs state as follows: 1. On February 12, 2008, plaintiffs filed their Motion for Partial Summary Judgment on Liability. 2. On March 28, 2008, after receiving three unopposed extensions of time from the Court, defendant filed its Cross-Motion for Summary Judgment and Opposition to Plaintiffs' Motion for Partial Summary Judgment. Defendant's motion and supporting memorandum are fifty-four pages in length, and defendant has filed a 683 page Appendix. 3. Under RCFC 7.2, plaintiffs' combined reply brief in support of their motion for partial summary judgment and response in opposition to defendant's cross-motion for summary judgment is presently due on April 25, 2008. 4. In order for plaintiffs to have adequate time to fully and succinctly address the relevant
Case 1:06-cv-00233-BAF
Document 132
Filed 04/14/2008
Page 2 of 2
issues in a combined reply brief in support of their motion and response in opposition to defendant's cross-motion, plaintiffs are requesting a two-week extension of time to and including May 9, 2008. This is the first extension sought by plaintiffs with respect to this pleading. 5. Counsel for defendant has told counsel for plaintiffs that defendant consents to this request. WHEREFORE, plaintiffs respectfully request that the Court grant this consent motion for an enlargement of time, to and including May 9, 2008, within which plaintiffs may file a combined reply/response to Defendant's Cross-Motion for Summary Judgment and Opposition to Plaintiffs' Motion for Partial Summary Judgment.
April 14, 2008
Respectfully submitted, s/ Stephen G. Seliger Attorney for plaintiffs Stephen G. Seliger Law Offices of Stephen G. Seliger 155 North Michigan Avenue Suite 501 Chicago, Illinois 60601 (312) 616-4244 (312) 565-7289 (telefax)
Of Counsel: Joel M. Hellman 155 North Michigan Avenue Suite 535 Chicago, Illinois 60601 (312) 616-3436 (312) 565-7289 (telefax) James G. Bradtke Soule, Bradtke & Lambert 155 North Michigan Avenue Suite 504 Chicago, Illinois 60601 (312) 616-4422 (312) 616-4423 (telefax)
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