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

Case 1:05-cv-00551-LJB

Document 46

Filed 04/03/2008

Page 1 of 3

IN THE UNITED STATES COURT OF FEDERAL CLAIMS HM2 CORPORATION, d/b/a HM2 CONSTRUCTORS AND FABRICATORS, Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) )

No. 05-551C (Judge Bush)

DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Defendant, the United States, respectfully requests the Court to grant an enlargement of time of seven days, to and including April 10, 2008, within which to file a reply to the motion for a protective order and motion for sanctions filed by the plaintiff, HM2 Corporation ("HM2"), on March 17, 2008. reply is currently due by April 3, 2008. This is our first Counsel for Our

request for an enlargement of time for this purpose.

HM2 has authorized us to state that HM2 does not oppose this motion. Because of the press of other business, counsel for the United States was unable to begin legal research and the drafting of our reply until Monday, March 31, 2008. When HM2 filed its

response, counsel was required to devote most of his time to the preparation of a formal brief in Mitchell Enterprises v. GSA, 2007-1579 (Fed. Cir.). 2008. Counsel filed that brief on March 25,

On March 26, 2008, counsel was required to travel to Counsel did not return to

Florida for depositions in this case. the office until March 31, 2008.

Case 1:05-cv-00551-LJB

Document 46

Filed 04/03/2008

Page 2 of 3

The full amount of additional time requested is needed. Counsel has completed substantial research and has begun drafting the reply. draft reply. However, additional time is needed to complete the In addition, time is needed for review of the draft

response by agency counsel and by supervisors at the Department of Justice. For the reasons stated above, we respectfully request that our unopposed motion for an enlargement of time be granted. Respectfully submitted, JEFFREY S. BUCHOLTZ Acting Assistant Attorney General JEANNE E. DAVIDSON Director S/ Harold D. Lester, Jr. HAROLD D. LESTER, JR. Assistant Director S/ James W. Poirier JAMES W. POIRIER Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor, 1100 L St, N.W Washington, D.C. 20530 Tele: 202-616-0856 Fax: 202-514-7969 April 3, 2008 Attorneys for Defendant

-2-

Case 1:05-cv-00551-LJB

Document 46

Filed 04/03/2008

Page 3 of 3

CERTIFICATE OF FILING I hereby certify that on April 3, 2008, a copy of the foregoing "DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME" 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. the Court's system. S/ James W. Poirier Parties may access this filing through