Free Motion for Extension of Time to File Response/Reply - District Court of Federal Claims - federal

Case 1:06-cv-00101-FMA

Document 32

Filed 03/24/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS

JAY CASHMAN, INC. Plaintiff, v. THE UNITED STATES, Defendant.

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No. 06-101C (Judge Francis M. Allegra)

PLAINTIFF'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME Pursuant to RCFC 6(b)(1) and 6.1, Plaintiff, Jay Cashman, Inc., by its counsel respectfully requests a 14-day enlargement of time, to and including April 14, 2008, to file Plaintiff's response to Defendant's Proposed Findings of Uncontroverted Fact, Defendant's Opposition to Plaintiff's Motion for Summary Judgment and Cross-Motion for Summary Judgment, and Defendant's Response to Plaintiff's Proposed Findings of Uncontroverted Statements of Fact. This is Plaintiff's second request for an enlargement of time for this purpose. Plaintiff's counsel has consulted with counsel for the Defendant, and Defendant has no objection to this request. In addition to this action, attorney of record for the Plaintiff has been engaged in a number of other matters before this Court including a matter (08-94C) in which the Government recently produced a voluminous 5200 page Administrative Record that has required a considerable amount of time for review and analysis. Counsel has also unexpectedly been required to schedule travel during the upcoming week that will make it difficult to complete its filing in time to meet the currently scheduled March 31, 2008 filing date. Counsel certainly does not contend that any other matter is more important than the case at hand and, in fact, it is the

Case 1:06-cv-00101-FMA

Document 32

Filed 03/24/2008

Page 2 of 2

equal importance of all of matters before the Court, and the desire to do the best possible work for all of our clients, that results in this request. An enlargement of time will enable Plaintiff's counsel to devote the time required to complete a reply to Defendant's opposition and to fully respond to Defendant's cross-motion. For the foregoing reasons, Plaintiff respectfully requests that the Court grant the unopposed motion for enlargement of time of fourteen days, to and including April 14, 2008, within which to file Plaintiff's response to defendant's opposition to plaintiff's motion for summary judgment and defendant's cross-motion for summary judgment. The Plaintiff further represents that no further enlargement of time will be requested Respectfully submitted,

Dated: March 24, 2008

/s/ Michael H. Payne Michael H. Payne, Esquire Payne Hackenbracht & Sullivan 220 Commerce Drive, Suite 100 Fort Washington, PA 19034 Tel: (215) 542-2777 Fax: (213) 542-2779 [email protected] Attorney of Record for Jay Cashman, Inc.

Of Counsel: Joseph A. Hackenbracht, Esquire Payne Hackenbracht & Sullivan

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