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

Case 1:05-cv-00400-FMA

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Filed 08/18/2005

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS MICHAEL W. STOVALL, Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 05-400C Judge Allegra

DEFENDANT'S SECOND UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Pursuant to Rule 6(b)(1) of the Rules of the United States Court of Federal Claims ("RCFC"), defendant, the United States, respectfully requests a 5-day enlargement of time, to and including August 23, 2005, to file the Government's reply to plaintiff's response to our motion to dismiss. Our response is currently due on August 18, 2005. This is defendant's second request for an enlargement of time for this purpose. The Court has previously granted the Government's request for a 7-day enlargement of time. Counsel for defendant has discussed this motion with Mr. Stovall's counsel, and he does not oppose this motion for enlargement. The United States requests this second brief enlargement of time because the Government's reply is still undergoing the review process within the Department of Justice. For the foregoing reasons, defendant respectfully requests that the Court grant this unopposed request for a 5-day enlargement of time. Respectfully submitted, PETER D. KEISLER Assistant Attorney General

Case 1:05-cv-00400-FMA

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Filed 08/18/2005

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DAVID M. COHEN Director s/Deborah A. Bynum DEBORAH A. BYNUM Assistant Director

OF COUNSEL: Ron Walkow Office of the General Counsel United States Department of Agriculture Washington, D.C.

s/Douglas K. Mickle DOUGLAS K. MICKLE Trial Attorney Commercial Litigation Branch Civil Division Department of Justice 1100 L Street, N.W. Attn: Classification Unit, 8th Floor Washington, D.C. 20530 Tele: (202) 307-0383 Fax: (202) 353-7988 Attorneys for Defendant

August 18, 2005

Case 1:05-cv-00400-FMA

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Filed 08/18/2005

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CERTIFICATE OF SERVICE

I hereby certify under penalty of perjury that on August 18, 2005, a copy of the foregoing "DEFENDANT'S SECOND UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME" was filed electronically. I understand that notice of this filing will be sent to all parties by operation of the Court's electronic filing system. Parties may access this filing through the Court's system.

s/Douglas K. Mickle Douglas K. Mickle