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

Case 1:05-cv-00608-ECH

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS FRANCISCO JAVIER RIVERA AGREDANO and ALFONSO CALDERON LEON, Plaintiffs, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 05--608C (Judge Hewitt)

DEFENDANT'S MOTION FOR AN ENLARGEMENT OF TIME Defendant respectfully requests an enlargement of time of four days, to and including December 2, 2005, within which to file its reply brief and response to plaintiffs' proposed additional facts. 28, 2005. Defendant's reply currently is due November

This is defendant's first request for an enlargement Plaintiffs' counsel has indicated that

of time for this purpose.

plaintiffs do not oppose this request. The requested enlargement of time is required so that counsel for defendant may have sufficient time to finalize and electronically file its reply brief and response to plaintiffs' proposed additional facts. Counsel's assigned reviewer was

unexpectedly away from the office, and accordingly additional time is necessary to complete internal review. For these

Case 1:05-cv-00608-ECH

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reasons, defendant respectfully requests that the Court grant its motion for an enlargement of time. Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director

s/ PATRICIA M. McCARTHY PATRICIA M. McCARTHY Assistant Director s/ PAUL R. WELLONS PAUL R. WELLONS Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L St., N.W. Washington, D.C. 20530 Tel: Fax: November 28, 2005 (202) 616-8253 (202) 307-0972

Attorneys for Defendant

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CERTIFICATE OF FILING I hereby certify that on November 28, 2005, a copy of the foregoing "MOTION FOR ENLARGEMENT" 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. may access this filing through the Court's system. s/ PAUL R. WELLONS Parties