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

Case 1:05-cv-00410-MMS

Document 68

Filed 05/14/2008

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS MARIO R. LOPEZ-VELAZQUEZ, Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 05-410C (Judge Sweeney)

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 an enlargement of time of 14 days, through and including May 29, 2008, within which we may file our reply brief in support of our motion for judgment upon the administrative record. Our reply brief is currently due on May 15, 2008. This is our second request for an enlargement of time for this purpose. Counsel for Mr. LopezVelazquez has indicated that Mr. Lopez-Velazquez is not opposed to this motion. This request for an enlargement of time is necessary to provide additional time to complete a draft of the brief and to obtain appropriate review. Government counsel is assigned to several matters requiring greater attention than previously anticipated that have delayed progress in completing a draft reply brief in this case, including Delpin-Aponte v. United States, Fed. Cl. No. 05-1043 (response to motion filed May 8, 2008), Gonzalez v. United States, Fed. Cl. No. 07-790 (discovery response served May 8, 2008); and Pat Huval Restaurant & Oyster Bar, Inc. v. United States, Ct. Int'l Trade No. 06-00290 (response to motion due May 16, 2008). In addition, Government counsel was out of the office on May 9 and May 12, 2008, and will be out of the office from May 19 to May 23, 2008. For these reasons, we respectfully request an

Case 1:05-cv-00410-MMS

Document 68

Filed 05/14/2008

Page 2 of 2

extension of time of 14 days, through and including May 29, 2008, within which we may file our reply brief.

Respectfully submitted, GREGORY G. KATSAS Acting Assistant Attorney General JEANNE E. DAVIDSON Director s/ Todd M. Hughes TODD M. HUGHES Deputy Director s/ Michael J. Dierberg MICHAEL J. DIERBERG Trial Attorney Department of Justice Civil Division Commercial Litigation Branch 1100 L. Street, NW Attn: Classification Unit 8th Floor Washington, D.C. 20530 Tel: (202) 353-0536 Fax: (202) 305-7643 May 14, 2008 Attorneys for Defendant

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