Free Motion for Extension of Time to File Response/Reply - District Court of Federal Claims - federal

Case 1:05-cv-01020-MMS

Document 12

Filed 12/20/2005

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

No. 05-1020C Judge Robert H. Hodges, Jr.

PLAINTIFF'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME TO RESPOND TO DEFENDANT'S MOTION TO DISMISS Plaintiff American International Specialty Lines Insurance Company ("Plaintiff" or "AISLIC"), by counsel, pursuant to Rules 6(b) and 6.1 of the Rules of the United States Court of Federal Claims ("RCFC"), respectfully requests an enlargement of time within which to file its response to Defendant's Motion to Dismiss the Transfer Complaint For Lack of Ripeness or, in the Alternative, to Dismiss Counts 1 and 2 for Failure to State a Claim and to Dismiss Count 3 for Lack of Jurisdiction ("Motion to Dismiss"). Defendant, the United States, filed its Motion to Dismiss on November 29, 2005. AISLIC requests an enlargement of 28 days to respond to the Motion to Dismiss, through January 27, 2006. This is AISLIC's first request for an enlargement of time for the purpose of responding to the Motion to Dismiss. Defendant's counsel has agreed to this enlargement. On December 20, 2005, concurrent with this motion, Plaintiff filed a Motion for Leave to Substitute Counsel. AISLIC requests the enlargement of time to allow Plaintiff's new counsel sufficient time to prepare an appropriate response to the Motion to Dismiss. For the foregoing reasons, Plaintiff AISLIC respectfully requests that the Court grant this unopposed motion for an enlargement of time to and including January 27, 2006, within which to respond to Defendant's Motion to Dismiss.

Case 1:05-cv-01020-MMS

Document 12

Filed 12/20/2005

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Respectfully submitted, s/T. Michael Guiffré T. Michael Guiffré Benjamin G. Chew (pending admission pro hac vice) J. Gordon Arbuckle Daniel R. Addison (pending admission pro hac vice) 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 20, 2005

Case 1:05-cv-01020-MMS

Document 12

Filed 12/20/2005

Page 3 of 4

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

No. 05-1020C Judge Robert H. Hodges, Jr.

[PROPOSED] ORDER This matter having come before the Court on Plaintiff's Unopposed Motion for an Enlargement of Time to Respond to Defendant's Motion to Dismiss, this court finds just cause to GRANT same and rule as follows. Wherefore, it is hereby: ORDERED, that Plaintiff shall respond to Defendant's Motion to Dismiss by January 27, 2006. So Ordered this _____ day of ____________, 20__.

Judge, U.S. Court of Federal Claims

Case 1:05-cv-01020-MMS

Document 12

Filed 12/20/2005

Page 4 of 4

CERTIFICATE OF FILING I certify that on December 20, 2005, the foregoing motion 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