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

Case 1:05-cv-00400-FMA

Document 13

Filed 08/10/2005

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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 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 7-day enlargement of time, to and including August 18, 2005, to file the Government's reply to plaintiff's response to our motion to dismiss. Pursuant to RCFC Rules 6(e) and 7.1, our response is currently due on August 11, 2005. This is defendant's first request for an enlargement of time for this purpose. 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 brief enlargement of time because counsel for defendant has just received comments from the Department of Agriculture concerning plaintiff's response, and needs this additional time to incorporate the agency's comments into the Government's reply, and have the reply reviewed by his supervisors. For the foregoing reasons, defendant respectfully requests that the Court grant this unopposed request for a 7-day enlargement of time. Respectfully submitted, PETER D. KEISLER Assistant Attorney General

Case 1:05-cv-00400-FMA

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Filed 08/10/2005

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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 8, 2005

Case 1:05-cv-00400-FMA

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Filed 08/10/2005

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CERTIFICATE OF SERVICE

I hereby certify under penalty of perjury that on August 10, 2005, a copy of the foregoing "DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME" with its accompanying appendix 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