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

Case 1:05-cv-01043-VJW

Document 35

Filed 12/11/2006

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS NO: 05-1043C

JORGE A. DELPIN APONTE, et al., v. UNITED STATES OF AMERICA

MOTION FOR EXTENSION OF TIME UNTIL WEDNESDAY, DECEMBER 13, 2006

BEFORE THE HONORABLE COURT: COMES NOW Plaintiffs in the above captioned complaint and as further detailed, through undersigning counsel, respectfully STATE and PRAY:

1.

Unfortunately and with all due respect to the Honorable Court and to

brother counsel, undersigning counsel could not complete the motion for filing today. As of the time of filing of this motion, we are still making the final changes to the draft, including review of certain legal references in an attempt to file it sometime tonight. 2. We consulted brother counsel, Mr. Jeffrey Pease, counsel for defendant,

regarding a one day extension to complete our filing, and Mr. Pease indicated his agreement with such a request. 3. that we Although, at the time we are filing this Motion, we have honestly realized might need two more days instead of one to complete our

Opposition/Response. Unfortunately, at this time, we could not contact attorney Pease either by phone or email to discuss the extension of time of two days.

Case 1:05-cv-01043-VJW

Document 35

Filed 12/11/2006

Page 2 of 2

4.

Plaintiffs respectfully request a brief extension of time, until Wednesday,

December 13, 2006 to file their opposition and/or responses to the defendant's motion to dismiss, for summary judgment and statement of purported undisputed facts as reflected in the record. WHERETORE, plaintiffs move the Court for an extension of time until Wednesday, December 13, 2006 to file their opposition and/or responses to defendant's motion to dismiss, for summary judgment and statement of purported undisputed facts as reflected in the record.

Respectfully submitted, S/ Santiago F. Lampon SANTIAGO F. LAMPON LAMPÓN & ASSOCIATES PO BOX 363641 SAN JUAN, PR 00936-3641 Tel: (787) 273-6767 Fax: (787) 758-3679 Attorney for Plaintiffs

December 11, 2006

CERTIFICATE OF SERVICE I hereby certify that on this 11th day of December, 2006, a copy of the foregoing "Informative Motion" has been 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/ Santiago F. Lampon

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