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

Case 1:05-cv-01043-VJW

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Filed 09/10/2008

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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

UNOPOSSED MOTION FOR ADDITIONAL 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 couple of days, undersigning counsel has

worked in earnest to complete the motions for filing today. Notwithstanding this effort, I have had to confront the reality that I will not be able to complete this work by today. 2. After discussing this subject with Defendant's counsel, Mr. Dielberg, we see best that plaintiffs request an

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extension of time until Monday, September 15, 2008 to file this motions. Though we will try to complete these documents by

Friday, September the 12th, we want to avoid the filing of an

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additional motion for extension of time and rather offer a final date plaintiffs feel they can comply with. 3. Defendant has not objection to the request, but would like

the filing dates for their oppositions to be adjusted by one week, which is the total amount of additional time plaintiffs have requested. Of course, plaintiffs are in agreement with

this request by the Defendant. WHERETORE, plaintiffs move this Honorable Court to grant the extension of time as request, allowing for the filing of the motion for summary judgment and the motion for class

certification to be filed on Monday, September 15, 2008, and also to move Defendant's timetable for the filing of the

respective oppositions by one week from the dates previously scheduled. Respectfully submitted, S/ Santiago F. Lampón

SANTIAGO F. LAMPÓN LAMPÓN & ASSOCIATES PO BOX 363641 SAN JUAN, PR 00936-3641 Tel: (787) 273-6767 Fax: (787) 395-7060 Attorney for Plaintiffs September 10, 2008 CERTIFICATE OF SERVICE I hereby certify that on this same date, a copy of the foregoing motion has been filed electronically. I understand

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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. Lampón