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

Case 1:05-cv-00580-TCW

Document 23

Filed 03/30/2006

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS ____________________________________ ) ) ) ) Plaintiff, ) ) v. ) ) THE UNITED STATES ) ____________________________________) CITY CRESCENT LIMITED PARTNERSHIP,

No. 05-580 (Judge Wheeler)

DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME Pursuant to Rule 6(b) of the Rules of the United States Court of Federal Claims, defendant, the United States, respectfully requests a ten day enlargement of time within which to file its response to plaintiff's cross motion for summary judgment and its reply brief in support of the Government's motion for summary judgment ("Government's response"). The Government's response is currently due March 31, 2006. The extension would bring the date for filing the motion to April 10, 2006. This is defendant's first request for an enlargement of time for this purpose. Counsel for plaintiff has indicated that plaintiff is not opposed to this motion. The request for enlargement is necessary due to the recent birth of counsel for defendant's second child. Counsel's second child, originally due April 2, 2006, was born on March 21, 2006. Since that time, counsel for defendant has been on leave every day except one, and has not had adequate time to prepare the Government's response. For these reasons, we respectfully request that the Court grant defendant's motion for an enlargement of time of ten days, to and including April 10, 2006, within which to file the Government's response.

Case 1:05-cv-00580-TCW

Document 23

Filed 03/30/2006

Page 2 of 2

Respectfully Submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director /s/ Deborah A. Bynum DEBORAH A. BYNUM Assistant Director /s/ Michael J. Dierberg MICHAEL J. DIERBERG Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit, 8th Floor 1100 L. St. NW Washington, DC 20530 Telephone: (202) 353-0536 Facsimile: (202) 307-0972 March 30, 2006 Attorneys for Defendant