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

Case 1:05-cv-00396-MCW

Document 21

Filed 10/27/2005

Page 1 of 2

No. 05-396C (Judge Mary Ellen Coster Williams) ________________________________________________________________________ IN THE UNITED STATES COURT OF FEDERAL CLAIMS ________________________________________________________________________ THOMAS L. REMPFER and RUSSELL E. D1NGLE, Plaintiffs, v. THE UNITED STATES, Defendant. ________________________________________________________________________ CONSENTED-TO PLAINTIFFS' MOTION FOR EXTENSION OF TIME NOW COME the plaintiffs, by and through their undersigned counsel, to respectfully move the Court for an extension of time to on or before Wednesday, November 16, 2005, in which to file his Reply to the Government's Opposition. During the period of time since the Government filed its pleading and through the date upon which the extension is sought, plaintiffs' counsel was out of the office for more than a week until returning on September 17, 2005, had a Motion for Summary Judgment due before the U.S. District Court for the District of Columbia in a case involving five years worth of litigation on September 19, 2005, was again out of the office from September 20-24, 2005, had a hearing before the Defense Office of Hearings & Appeals on September 26, 2005, has a security clearance filing due at the Central Intelligence Agency on October 31, 2005, has another Motion for Summary Judgment due in another case also before the U.S. District Court for the District of Columbia on November 1, 2005, a Petition for Certiorari due at the U.S. Supreme Court on November 3, 2005, a security clearance filing due with the Defense Office of Hearings & Appeals on November 7, 2005, an Opposition brief in the first litigation case referenced above also due November 7, 2005, and will be out of the office from November 10-13, 2005.

Case 1:05-cv-00396-MCW

Document 21

Filed 10/27/2005

Page 2 of 2

Plaintiffs' counsel discussed this request with defendant's counsel, who indicated the Government consents to the extension. The granting of this motion shall not result in the continuance of any hearing, conference or trial. A proposed Order accompanies this Motion. Date: October 27, 2005 Respectfully submitted, s/Mark S. Zaid __________________________ Mark S. Zaid, Esq. DC Bar # 440532 Krieger & Zaid, PLLC 1920 N Street, N.W., Suite 300 Washington, DC 20036 (202) 454-2809 (202) 293-4827 fax [email protected]