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

Case 1:06-cv-00224-MCW

Document 23

Filed 06/11/2007

Page 1 of 3

IN THE UNITED STATES COURT OF FEDERAL CLAIMS JOHN HERDA and MARGARET HERDA JOHN J. HERDA and SUSAN M. HERDA NICHOLAS HERDA and JODI LYNN HERDA Plaintiffs, v. UNITED STATES OF AMERICA Defendant. § § § § § § § § § § § § § § § §

CIVIL NO.06-224T Judge Mary Ellen Coster Williams

UNOPPOSED MOTION TO RESET DEADLINES By Order dated June 7, 2007, this Court re-set by two weeks the deadlines for filing motions for summary judgment in this case. For the reason stated below the Plaintiffs now request that those deadlines each be extended again by four weeks as follows: 1. 2. Plaintiffs shall file their motion for summary judgment on or before July 13, 2007; Defendant shall file any response to Plaintiffs' motion for summary judgment and any cross-motion for summary judgment on or before August 17, 2007; 3. Plaintiffs shall file any reply in support of their motion for summary judgment and any response to Defendant's cross-motion for summary judgment on or before September 14, 2007; and 4. Defendant shall file any reply in support of its cross-motion for summary judgment on or before October 5, 2007. Plaintiffs would show the following as good cause for this request:
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Case 1:06-cv-00224-MCW

Document 23

Filed 06/11/2007

Page 2 of 3

Plaintiffs' counsel with primary responsibility for research and drafting the Plaintiffs' motion for summary judgment in this case, and with similar responsibilities in the related Elektra partnership-related cases, is Sallie W. Gladney. On June 9, 2007, Ms. Gladney was informed that her great aunt has been diagnosed with terminal liver cancer and has been moved to a hospice. Ms. Gladney is particularly close to this lady who lives in Jackson, Mississippi, an 8-hour drive from our offices in Houston, Texas. The lady, Miss Gladys Clement, is expected to pass away within the next few weeks. Ms. Gladney is leaving to drive to Jackson on the evening this motion is filed and is scheduled to return on Thursday, June 14, 2007. Ms. Gladney anticipates that she will be making at least two more trips to Mississippi within the next month. Plaintiffs' counsel regrets the necessity of asking for additional time on this matter and will make every possible effort to file the Plaintiffs' motion for summary judgment before the requested deadline of July 13, 2007. Defendant's counsel was contacted and represented that the United States does not object to the granting of this motion. WHEREFORE, Plaintiffs respectfully request that deadlines for filing motions for summary judgment and all responsive pleadings be extended by four weeks. Respectfully, /s/ Thomas E. Redding Thomas E. Redding Texas State Bar No. 16661300 Redding & Associates, P.C. 2914 W. T.C. Jester Houston, Texas 77018 (713) 965-9244 (713) 621-5227 (Fax) ATTORNEY FOR PLAINTIFFS 2
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Case 1:06-cv-00224-MCW

Document 23

Filed 06/11/2007

Page 3 of 3

Of Counsel for Plaintiffs: Sallie W. Gladney Texas State Bar No. 00787546 Teresa J. Womack Texas State Bar No. 00788707 Redding & Associates, P.C. 2914 W. T.C. Jester Houston, Texas 77018 (713) 965-9244 (713) 621-5227 (Fax)

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