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

Case 1:06-cv-00232-LMB

Document 47

Filed 01/31/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS **************************************** * SYSTEMS DEVELOPMENT * CORPORATION, * Plaintiff, * * v. * * UNITED STATES, * Defendant, * * ****************************************

Filed: January 31, 2008

Case No. 06-232C (Judge Baskir)

PLAINTIFF'S MOTION TO EXTEND TIME FOR PLAINTIFF'S BRIEF PURSUANT TO THE COURT'S DECEMBER 19, 2007 ORDER Comes now the Plaintiff, Systems Development Corporation, pursuant to Rule 6.1 of the Rules of the United States Court of Federal Claims, and prays this Honorable Court to extend the time for the Plaintiff to file its supplementary brief upon the issues stated in the Court's December 19, 2007, Order. In support of this motion, the Plaintiff would show unto the Court as follows: 1. On December 19, 2007, subsequent to oral argument on the parties' respective motions for summary judgment, the Court ordered the parties to submit additional briefs on four (4) distinct issues. 2. 3. The current deadline for the filing of the Plaintiff's Brief is January 31, 2008. Plaintiff has not filed any previous motions to extend time for filing its brief.

4. Joan M. Stentiford, Counsel for the Defendant has been informed of the Plaintiff's intent to file this Motion, and has given her consent to the averments and prayer herein. 5. The Plaintiff states as cause for this motion that its counsel has been unable to finalize its brief due to conflicting obligations concerning its firm, and the death of a friend of the family. WHEREFORE, the premises considered, the Plaintiff prays this Honorable Court to extend the deadline for the filing of the Plaintiff's Response to the Defendant's motion by (2) days, thereby establishing a new deadline of February 4, 2008. This Motion is respectfully submitted on this the 31st day of January, 2008.

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Case 1:06-cv-00232-LMB

Document 47

Filed 01/31/2008

Page 2 of 2

/s/ Howell Roger Riggs_________________ Howell Roger Riggs Attorney for the Plaintiff

OF COUNSEL: Dick Riggs Miller LLP 200 Clinton Avenue West AmSouth Center, Suite 1050 Huntsville, Alabama 35801 Tel: (256) 564-7317 Fax: (256) 564-7319 [email protected]

CERTIFICATE OF SERVICE I hereby certify that on the 31st day of January, 2008, I caused a copy of the foregoing motion to be served on the following parties via electronic mail, and by placing the same in the U.S. Mail, properly addressed and postage prepaid: Joan M. Stentiford Attorney for the Defendant Commercial Litigation Branch Civil Division Department of Justice 1100 L Street, N.W. Attn: Classification Unit 8th Floor Washington, D.C. 20530 Tel: (202) 616-0341 Fax: (202) 514-8624

/s/ Howell Roger Riggs_______________________ Howell Roger Riggs

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