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

Case 1:05-cv-01043-VJW

Document 32

Filed 12/04/2006

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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

BEFORE THE HONORABLE COURT: COMES NOW Plaintiffs in the above captioned complaint and as further detailed, through undersigning counsel, respectfully STATE and PRAY: 1. During the last week, we met with plaintiffs and other terminals on various

occasions, identified and reproduced a series of documents to be used in support of our response to defendant's motion and statement of proposed undisputed facts, and identified certain data which will be further discussed in our response. 2. At this time, we have a couple of documents which have not been made

available to us for copying and filing, mostly because the custodian of the individual associated with these records, co-plaintiff Ricardo Rivera, has very limited availability to assist in the identification and production of these documents as a result of a terminal illness he has been suffering. 3. The combination of these facts demands that we move the Court for an

additional short time extension of three (3) working days to complete our work, with the filing of our responses to be done on or before Friday, December 8, 2006.

Case 1:05-cv-01043-VJW

Document 32

Filed 12/04/2006

Page 2 of 2

4.

I spoke about this extension with Mr. Jeffrey Pease, counsel for

defendant, and Mr. Pease has no objection to the brief request made herein. WHERETORE, plaintiffs move the Court for an extension of time until Friday, December 8, 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 4, 2006

CERTIFICATE OF SERVICE I hereby certify that on this 4th day of December, 2006, a copy of the foregoing "Motion for Extension of Time" 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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