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

Case 1:05-cv-00738-TCW

Document 42

Filed 03/30/2007

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United States Court Of Federal Claims
BROWNING-FERRIS INDUSTRIES, INC. & SUBSIDIARIES, Plaintiff, v. UNITED STATES OF AMERICA, Defendant. ) ) ) ) ) ) ) ) ) ) )

No. 05-738T Judge Thomas C. Wheeler

PLAINTIFF'S MOTION FOR EXTENSION OF TIME TO FILE RESPONSE TO UNITED STATES' MOTION FOR RECONSIDERATION Plaintiff, by its attorneys, and pursuant to RCFC Rule 6.1, respectfully requests that this Court grant it a 10-day extension of time to file its response to Defendant's Motion for Reconsideration. As grounds for this request, Plaintiff submits as follows: 1. On March 26, 2007, this Court entered an order requesting Plaintiff to submit a

response to Defendant's Motion for Reconsideration on or before April 9, 2007. At the time the Court's order was issued, Plaintiff's counsel had committed to travel arrangements that required his absence from his office the majority of the week of March 26, 2007 through March 30, 2007, and the week of April 2, 2007 through April 6, 2007. Counsel's extended absence over such time period gives rise to this request for an extension, in order to allow counsel sufficient time upon his return to prepare Plaintiff's response. 2. On March 30, 2007, Plaintiff's counsel contacted Defendant's counsel by electronic

mail to solicit his consent to the requested extension. Defendant's counsel has replied that he has no objection to the requested extension. 3. No prior requests for an extension of time have been made to the Court.

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Case 1:05-cv-00738-TCW

Document 42

Filed 03/30/2007

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WHEREFORE, Plaintiff respectfully requests that the Court grant its motion to extend the deadline to respond to Defendant's motion to April 19, 2007. A proposed order reflecting the foregoing request is attached.

Respectfully submitted, /s/ Philip Karter PHILIP KARTER Chamberlain, Hrdlicka, White, Williams & Martin 300 Conshohocken State Road, Suite 570 West Conshohocken, PA 19428 610/772-2300 Telephone 610/772-2305 Facsimile Attorney of Record for Plaintiff HERBERT ODELL Chamberlain, Hrdlicka, White, Williams & Martin 300 Conshohocken State Road, Suite 570 West Conshohocken, PA 19428 610/772-2300 Telephone 610/772-2305 Facsimile Of Counsel Dated: March 30, 2007
0000231.01

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Case 1:05-cv-00738-TCW

Document 42

Filed 03/30/2007

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CERTIFICATE OF SERVICE It is hereby certified that service of the foregoing MOTION FOR EXTENSION OF TIME was made on this 30th day of March, 2007 by electronically filing a copy of the same with the Court under the CM/ECF system with notification of such filing to Defendant's counsel, Stuart J. Bassin.

/s/ Philip Karter PHILIP KARTER Chamberlain, Hrdlicka, White, Williams & Martin 300 Conshohocken State Road, Suite 570 West Conshohocken, PA 19428 610/772-2300 Telephone 610/772-2305 Facsimile

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