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

Case 1:05-cv-01043-VJW

Document 30

Filed 11/27/2006

Page 1 of 2

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. In the captioned case, plaintiffs have pending the filing of a motion in response to defendant USPS Partial Motion to Dismiss and Motion for Summary Judgment. 2. Plaintiffs are in the final stages of completing their responses thereof, but certain tasks are pending yet they are close to being completed. For instance, certain statements under penalty of perjury have to be completed and the individuals who will execute them be available prior to filing. Moreover, certain documents which will accompany the motion have not been made available to undersigning counsel, but should be ready for filing in a couple of days. 3. Plaintiffs need 5 working days, until Monday, December 4, 2006 to complete these tasks and file their response to the motion and the statement filed by Defendant. 4. Undersigning counsel contacted attorney Mr. Jeffrey Pease, who stated that he has no objection to this request.

Case 1:05-cv-01043-VJW

Document 30

Filed 11/27/2006

Page 2 of 2

WHERETOFORE plaintiffs respectfully request 5 working days for extension of time to oppose or otherwise plead in response to the various filings presented by defendant as reflected by 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

November 27, 2006

CERTIFICATE OF SERVICE I hereby certify that on this 27th day of November, 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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