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

Case 1:05-cv-00675-MMS

Document 36

Filed 07/24/2007

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS No. 05-675 T (Judge Margaret M. Sweeney) __________ WILLIAM F. AND THERESE HARTMAN, Plaintiffs v. UNITED STATES, Defendant

__________ MOTION FOR EXTENSION OF TIME _________

The defendant, pursuant to RCFC 6(b), respectfully moves this Court for an enlargement of four days, from July 23, 2007, to and including July 27, 2007, of the deadline for the defendant to respond to plaintiff's discovery requests. No prior enlargement of this deadline has been requested. Defendant's counsel has contacted plaintiffs' counsel who has stated that plaintiffs do not oppose this motion. As good cause therefore, defendant requires some additional time to complete its responses to plaintiffs' discovery requests. Further, the responses have to be reviewed by counsel handling similar cases in United States District Courts to ensure that the position of the defendant in these cases is consistent. This process will take some additional time. Defendant's

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Case 1:05-cv-00675-MMS

Document 36

Filed 07/24/2007

Page 2 of 2

counsel has agreed to e-mail the discovery responses to plaintiffs' counsel on July 27, 2007, so he can review them as soon as possible. WHEREFORE, defendant respectfully requests that the Court enlarge the deadline for the defendant to respond to plaintiffs' discovery to July 27, 2007.

Respectfully submitted,

s/Benjamin C. King, Jr. BENJAMIN C. KING, JR. Attorney of Record Justice Department (Tax) Court of Federal Claims Section Post Office Box 26 Ben Franklin Post Office Washington, D.C. 20044 (202) 307-6506 RICHARD T. MORRISON Acting Assistant Attorney General DAVID GUSTAFSON Chief, Court of Federal Claims Section STEVEN I. FRAHM s/Steven I. Frahm Of Counsel July 24, 2007

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1427097.1