Free Motion for Leave to File - District Court of Federal Claims - federal

Case 1:05-cv-01043-VJW

Document 22-2

Filed 09/13/2006

Page 1 of 1

IN THE UNITED STATES COURT OF FEDERAL CLAIMS

JORGE A. DELPIN-APONTE, ET AL., Plaintiffs, v. THE UNITED STATES, Defendant.

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No. 05-1043C (Judge Wolski)

UNCONTESTED 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. Defendant in the captioned case, filed a motion to dismiss and for summary judgment, presenting various

arguments which purportedly support such proposition. Defendant's motion is ample and requires extensive review in order to properly and responsibly prepare a response. 2. Undersigning counsel estimates that a term of 30 days is needed in order to adequately prepare an opposition

to defendants' motion and defendants' statement of purported uncontested facts. 3. Undersigning counsel has consulted with counsel for defendants, Mr. Jeffrey Pease and he has agreed to the

extension requested under this statement. WHERETOFORE plaintiff requests that the stated extension of time be granted as requested, with the filing by defendants due on or before October 12, 2006.

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

September 11, 2006

CERTIFICATE OF SERVICE I hereby certify that on this 11 day of September 2006, a copy of the foregoing "Uncontested Motion for Extension 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.
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S/ Santiago F. Lampon