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

Case 1:05-cv-01192-LJB

Document 9

Filed 05/01/2006

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS

MICHAEL J. DONAHUE, Plaintiff, v. UNITED STATES OF AMERICA, Defendant.

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Case No. 05-1192C (Judge Lynn J. Bush)

MOTION FOR ENLARGEMENT OF TIME Plaintiff hereby moves for an enlargement of time from May 1, 2006 up to and including May 15, 2006 to file his motion for summary judgment herein. The basis for such request is as follows: 1. On January 5, 2006, plaintiffs submitted a proposed settlement to defendant for the purpose of resolving the claims herein. 2. On March 3, 2006, the parties filed a joint preliminary status report pursuant to Appendix A, Par. 4 of the Rules of the United States Court of Federal Claims. Plaintiff represented that he intended to file a dispositive motion if the settlement agreement was not approved by May 1, 2006. 3. Counsel for defendant has represented to counsel for plaintiff that the proposed settlement agreement will be submitted for approval by May 15, 2006, assuming minor differences in the back pay due can be resolved. 4. Therefore, plaintiff requests an enlargement of time up to and including May 21, 2006, to file his dispositive motion herein.

Case 1:05-cv-01192-LJB

Document 9

Filed 05/01/2006

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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: May 1, 2006

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Case 1:05-cv-01192-LJB

Document 9

Filed 05/01/2006

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CERTIFICATE OF FILING I hereby certify under penalty of perjury that on this 1st day of May 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

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