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

Case 1:05-cv-01020-MMS

Document 36

Filed 12/21/2006

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS ) ) ) Plaintiff, ) ) v. ) ) UNITED STATES OF AMERICA, ) ) Defendant. ) __________________________________________) AMERICAN INTERNATIONAL SPECIALTY LINES INSURANCE COMPANY,

No. 05-1020C Judge Margaret M. Sweeney

PLAINTIFF'S MOTION FOR ENLARGEMENT OF TIME Pursuant to Rules 6 and 6.1 of the Court's Rules ("RCFC"), Plaintiff American International Specialty Lines Insurance Company ("Plaintiff" or "AISLIC"), by and through its undersigned attorneys, and with Defendant's consent, respectfully submits this Motion for Enlargement of Time, from December 22, 2006, to and including January 5, 2007, for its response to the Court's Order of November 30, 2006. This is AISLIC's first such request for an enlargement of time for the purpose of responding to the Court's Order. In its Order, dated November 30, 2006, the Court directed Plaintiff to file a memorandum explaining why it should not construe Plaintiff's actions as a waiver or forfeiture of its right to conduct discovery to address the issues Defendant raises in its Motion to Dismiss, or in the Alternative, for Summary Judgment, filed on July 12, 2006. Plaintiff has diligently reviewed and compiled information for its response to the Court's Order. However, Plaintiff seeks additional time to complete the response and to confer internally to address certain issues concerning the response. Plaintiff became aware of the need for a short enlargement of time on Thursday, December 21, 2006. It promptly contacted Defendant's counsel, who agreed to this enlargement on behalf of

Case 1:05-cv-01020-MMS

Document 36

Filed 12/21/2006

Page 2 of 3

Defendant. Under these circumstances, the requested enlargement of time is reasonable and should result in no undue delay, prejudice, or inconvenience. CONCLUSION Accordingly, we respectfully request that the Court grant this unopposed motion for an enlargement of time to and including January 5, 2007, within which to respond to the Court's Order of November 30, 2006. Respectfully submitted, s/T. Michael Guiffré T. Michael Guiffré J. Gordon Arbuckle Daniel R. Addison PATTON BOGGS LLP 2550 M Street, N.W. Washington, D.C. 20037 Telephone: (202) 457-6000 Facsimile: (202) 457-6315 Attorneys for Plaintiff American International Specialty Lines Insurance Company December 22, 2006

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Case 1:05-cv-01020-MMS

Document 36

Filed 12/21/2006

Page 3 of 3

CERTIFICATE OF FILING I certify that on December 22, 2006, the foregoing Plaintiff's Motion for Enlargement 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.

s/T. Michael Guiffré T. Michael Guiffré

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