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

Case 1:05-cv-00410-MMS

Document 56

Filed 02/20/2008

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 (Chief Judge Damich)

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 six days, through and including February 27, 2007, within which we may file our response to plaintiff's motion to remand. Our response brief is currently due on February 21, 2007. This is our third request for an enlargement of time for this purpose. Counsel for Mr. Lopez-Velazquez 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 had anticipated devoting significant attention to drafting the brief from February 16, 2008 to February 18, 2008. However, Government counsel was incapacitated with the flu during that time period. Although Government counsel has sufficiently recovered to continue working on the draft brief, additional time is necessary to complete the draft and to obtain appropriate review. For these reasons, we respectfully request an extension of time of six days, through and including February 27, 2008, within which we may file our response brief.

Case 1:05-cv-00410-MMS

Document 56

Filed 02/20/2008

Page 2 of 2

Respectfully submitted, JEFFREY S. BUCHOLTZ 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 February 20, 2008 Attorneys for Defendant