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

Case 1:05-cv-00503-TCW

Document 32

Filed 03/27/2007

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS ) ) ) ) ) ) ) ) ) ) ) )

HOSPITAL SERVICE ASSOCIATION OF NORTHEASTERN PENNSYLVANIA, Plaintiff, v. THE UNITED STATES OF AMERICA, Defendant.

Civil Action No. 05-503 T Judge Thomas C. Wheeler

PLAINTIFF'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME IN WHICH TO FILE ITS BRIEF IN RESPONSE TO DEFENDANT'S MOTION FOR SUMMARY JUDGMENT Pursuant to Rule 6.1 of the Rules of the United States Court of Federal Claims, Plaintiff Hospital Service Association of Northeastern Pennsylvania hereby respectfully moves for an enlargement of time in which to file its brief in response to Defendant's motion for summary judgment. Presently, Plaintiff's brief is due on April 2, 2007. Plaintiff requests an enlargement of 28 days, which would make its brief due on April 30, 2007. The due date for Plaintiff's brief in response to Defendant's motion for summary judgment has not been enlarged previously. Plaintiff requests this enlargement of time because it requires additional time to review and respond to Defendant's numerous legal arguments and voluminous factual filings in support of its motion. These factual filings total more than 200 pages in length. Counsel for Plaintiff has discussed this motion with counsel for Defendant who stated that Defendant does not oppose this motion and will not file an opposition.

1

745437.1

Case 1:05-cv-00503-TCW

Document 32

Filed 03/27/2007

Page 2 of 2

WHEREFORE, Plaintiff Hospital Service Association of Northeastern Pennsylvania respectfully asks this Court to grant an enlargement of time until April 30, 2007, for Plaintiff to file its brief in response to Defendant's motion for summary judgment. Respectfully submitted, ______s/ Frederick H. Robinson _______ Frederick H. Robinson MILLER & CHEVALIER CHARTERED 655 Fifteenth Street, N.W. Suite 900 Washington, D.C. 20005 (202) 626-5800 (202) 628-0858 (facsimile) Counsel of Record for Plaintiff Of Counsel: Clarence T. Kipps, Jr. Maria O. Jones Adam P. Feinberg MILLER & CHEVALIER CHARTERED 655 Fifteenth Street, N.W. Suite 900 Washington, D.C. 20005 (202) 626-5800 (202) 628-0858 (facsimile) Dated: March 27, 2007

2

745437.1