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

Case 1:05-cv-00410-MMS

Document 55

Filed 02/13/2008

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 21, 2007, within which we may file our response to plaintiff's motion to remand. Our response brief is currently due on February 15, 2007. This is our second 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 is assigned to two matters which have unexpectedly required greater attention than previously anticipated, including Target Corp. v. United States, C.I.T. No. 05-0346 (supplemental oral argument held February 12, 2008), and Dental EZ v. United States, C.I.T. No. 07-0029 (motion to dismiss and motion for judgment upon the administrative record due February 29, 2008). These and other matters have delayed progress in drafting our response in this case. For these reasons, we respectfully request an extension of time of six days, through and including February 21, 2008, within which we may file our response brief.

Case 1:05-cv-00410-MMS

Document 55

Filed 02/13/2008

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 13, 2008 Attorneys for Defendant