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

Case 1:05-cv-01189-CFL

Document 48

Filed 11/05/2007

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS THOMAS H. McGANN and EVELYN G. McGANN Plaintiffs, v. UNITED STATES OF AMERICA Defendant. § § § § § § § § §

CIVIL NO. 05-1189 JUDGE LETTOW

PLAINTIFFS' UNOPPOSED MOTION FOR ENLARGEMENT OF TIME TO FILE STIPULATIONS OF FACT AND MOTION FOR SUMMARY JUDGMENT Plaintiffs Thomas H. McGann and Evelyn G. McGann ("the McGanns") respectfully request an enlargement of time of two days until Wednesday, November 7, 2007, for the parties to file their Joint Stipulations of Fact and for the plaintiffs to file their motion for summary judgment and in support would show: The Joint Stipulations of Fact and for the plaintiffs motion for summary judgment are due to be electronically filed today, November 5, 2007. On October 26, 2007, government counsel sent proposed stipulations of fact to the plaintiffs' counsel. While drafting the plaintiffs' motion for summary judgment plaintiffs' counsel significantly revised the proposed stipulations and was not able to send the revised proposed stipulations, with all exhibits, back to government counsel until the morning of Friday, November 2, 2007. Government counsel was not able to review the revised proposed stipulations and exhibits until late that afternoon. Government counsel advised that he did not anticipate substantial additional changes but would need adequate time to review the new materials and to obtain approval for the final version through the government's normal channels. Plaintiffs' counsel apologizes for any inconvenience caused by the need for the brief enlargement requested.
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Case 1:05-cv-01189-CFL

Document 48

Filed 11/05/2007

Page 2 of 2

Government counsel has represented that the United States does not oppose the granting of this motion. WHEREFORE, Plaintiffs Thomas H. McGann and Evelyn G. McGann respectfully request an enlargement of time of two days until Wednesday, November 7, 2007, for the parties to file their Joint Stipulations of Fact and for the plaintiffs to file their motion for summary judgment. Respectfully, /s/ Sallie W. Gladney Sallie W. Gladney Texas State Bar No. 00787546 Redding & Associates, P.C. 2914 W. T.C. Jester Houston, Texas 77018 (713) 965-9244 (713) 621-5227 (Fax) ATTORNEY FOR PLAINTIFFS Of Counsel for Plaintiffs: Teresa J. Womack Texas State Bar No. 00788707 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) CERTIFICATE OF CONFERENCE On Friday, November 2, 2007, Sallie W. Gladney, counsel for Plaintiffs Thomas H. McGann and Evelyn G. McGann, spoke with Mr. Bob Stoddart, counsel for the United States, who stated that the United States is unopposed to the granting of the forgoing motion. /s/ Sallie W. Gladney Sallie W. Gladney

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