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

Case 1:06-cv-00103-LJB

Document 11

Filed 09/28/2006

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS

LYDIA Y. BAGLEY, et al. Plaintiffs, v. UNITED STATES OF AMERICA, Defendant.

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Case No. 06-103C (Judge Lynn J. Bush)

PLAINTIFFS' MOTION FOR ENLARGEMENT OF TIME TO FILE DISPOSITIVE MOTIONS Plaintiffs hereby request an enlargement of time to file their dispositive motions in the above-captioned case from October 31, 2006 to February 6, 2007. Plaintiffs are currently scheduled to file their dispositive motion on October 31, 2006 for plaintiffs who occupy or who have occupied the position of diversion investigator at the Drug Enforcement Administration. Because it now appears likely that the parties will be able to resolve the claims of these plaintiffs by settlement, plaintiffs request an enlargement of time until February 6, 2007 to file their dispositive motion in this case. Defendant's counsel has authorized plaintiffs' counsel to represent that he has no objection to the granting of the instant request.

Case 1:06-cv-00103-LJB

Document 11

Filed 09/28/2006

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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: September 28, 2006

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Case 1:06-cv-00103-LJB

Document 11

Filed 09/28/2006

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CERTIFICATE OF FILING I hereby certify under penalty of perjury that on this 28th day of September 2006, 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