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

Case 1:05-cv-01043-VJW

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Filed 11/13/2006

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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. Last week, the Governor of Puerto Rico, Aníbal Acevedo Vilá, invited

undersigning counsel and other individuals he identified as "religious leaders in Puerto Rico" for a breakfast meeting at his residence. I attended the meeting. 2. During the meeting, the Governor invited us to create and conduct events

of great magnitude to deplore and prevent the abuse of children in Puerto Rico, and declared November 12, 2006 as the Day Against the Abuse of Children. In representation of my church, I immediately started to lead the effort to support the Governor's initiative. 3. Contrary to what I was expecting or had anticipated, the preparation and

coordination of activities in response to the Governor's call have been quite demanding upon me and my staff who one way or the other are making this event possible.

Case 1:05-cv-01043-VJW

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4.

Inevitably and contrary to my expectations, the toll this activity has taken

on my already limited time has been overwhelming and was completely unanticipated. 5. Regretfully but understandably so (I hope), we need to move the Court for

two weeks extension to make room for the time otherwise dedicated to the event on behalf of the children, which my law firm is proudly supporting considering its broadness and the importance of its subject-matter. As a father of a 6 year old, I simply could not ignore or otherwise diminish the importance of the Governor's plead in light of my beliefs. 6. I have discussed this situation with counsel for defendant, Mr. Jeffrey

Pease, who did not oppose to our request for a two weeks extension. 7. The extension of time would end on November 27, 2006.

WHERETOFORE plaintiffs respectfully request a two weeks extension 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 LAMPON & ASSOCIATES PO BOX 363641 SAN JUAN, PR 00936-3641 Tel: (787) 273-6767 Fax: (787) 758-3679 Attorney for Plaintiffs

November 8, 2006

CERTIFICATE OF SERVICE 2

Case 1:05-cv-01043-VJW

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Filed 11/13/2006

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I hereby certify that on this 12th day of October, 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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