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

Case 1:06-cv-00101-FMA

Document 31

Filed 02/20/2008

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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 28-day enlargement of time, to and including March 31, 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 Facts. This is Plaintiff's first 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, the attorney of record for the Plaintiff has been engaged in a number of other cases before this Court that have occupied his attention in recent weeks and will require his continued involvement in the coming weeks. An enlargement of time is necessary so that Plaintiff's counsel can reply to Defendant's opposition and respond to Defendant's crossmotion. For the foregoing reasons, Plaintiff respectfully requests that the Court grant the unopposed motion for enlargement of time of twenty-eight days, to and including March 31,

Case 1:06-cv-00101-FMA

Document 31

Filed 02/20/2008

Page 2 of 3

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. Respectfully submitted,

Dated: February 20, 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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Case 1:06-cv-00101-FMA

Document 31

Filed 02/20/2008

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that on February 20, 2008, a copy of the foregoing "PLAINTIFF'S UNOPPOSED 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/ Michael H. Payne Michael H. Payne

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