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

Case 1:05-cv-00370-CFL

Document 18

Filed 11/01/2005

Page 1 of 2

No. 05-370C 1. (Judge Lettow) ______________________________________________________________________________ IN THE UNITED STATES COURT OF FEDERAL CLAIMS ADRIAN RODRIGUEZ AND ALI JAZMIN RODRIGUEZ Plaintiffs, v. UNITED STATES OF AMERICA Defendants. ______________________________________________________________________________ PLAINTIFFS' UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME ______________________________________________________________________________ TERESA TRUCCHI SBN# 135543 SUPPA, TRUCCHI, AND HENEIN, LLP 3055 India Street San Diego, CA 92103 Telephone: (619) 297-7330 Telefax : (619) 297-9658 Attorneys for PLAINTIFFS ADRIAN RODRIGUEZ AND ALI JAZMIN RODRIGUEZ

Case 1:05-cv-00370-CFL

Document 18

Filed 11/01/2005

Page 2 of 2

Plaintiffs request a final enlargement of time to oppose the motion for summary judgment and to dismiss filed by the USA. The date for the opposition was October 28, 2005. Counsel for the USA does not oppose this request. This is the first time counsel has filed such an extensive brief electronically and technical difficulties were encountered. The points and authorities were filed October 28, 2005 (Pacific Standard Time). However, as it was late in the evening, it was October 29, 2005 on Eastern Standard Time. Further attempts to file the remaining documents were unsuccessful until the Response to the Statement of Uncontroverted Facts was filed October 31, 2005. Then the ECF system apparently encountered problems and further efforts to file the balance of the documents were unsuccessful until today. I request an enlargement of time until tomorrow, November 2, 2005 to complete the filing of plaintiffs' opposition. The only document that remains to be filed is the plaintiffs' appendix with attachments. Plaintiffs counsel believes that this final document will be filed before close of business today. It is a large document and plaintiffs' counsel is still working on the proper format to file it. For the foregoing reasons, plaintiffs
respectfully request that the Court grant our unopposed m otion to enlarge the tim e within which to com plete the filing of the plaintiffs' opposition to the m otion for sum m ary judgm ent and to dism iss until Novem ber 2, 2005.

Dated:

TERESA TRUCCHI ATTORNEY FOR ADRIAN AND ALI JAZMIN RODRIGUEZ