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

Case 1:05-cv-00410-MMS

Document 54

Filed 01/11/2008

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 29 days, through and including February 15, 2007, within which we may file our response to plaintiff's motion to remand. Our response brief is currently due on January 17, 2007. This is our first 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 several matters that required significant attention shortly before counsel's absence during the holiday period, including Dus & Derrick, Inc. v. United States Dep't of Agriculture, C.I.T. No. 05-0346 (oral argument held December 19, 2007), and East Jordan Iron Works, Inc. v. United States, C.I.T. No. 07-0082 (dispositive brief filed December 21, 2007), which delayed progress in preparing a response brief in this case. Following counsel's return to the office on January 3, 2008, progress in drafting a response brief has been further delayed due to other matters requiring significant attention, including Fagersta Stainless AB v. United States, C.I.T. No. 070153 (dispositive brief due January 16, 2008), and Dental EZ, Inc. v. United States, C.I.T. No.

Case 1:05-cv-00410-MMS

Document 54

Filed 01/11/2008

Page 2 of 2

07-0029 (dispositive brief due January 30, 2008). For these reasons, we respectfully request an extension of time of 29 days, through and including February 15, 2008, within which we may file our response brief.

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 January 11, 2008 Attorneys for Defendant