Case 1:05-cv-00370-CFL
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IN THE UNITED STATES COURT OF FEDERAL CLAIMS
ADRIAN RODRIGUEZ and ALI JAZMIN RODRIGUEZ, Plaintiffs
v. THE UNITED STATES, Defendant.
) ) ) ) ) ) ) ) ) ) )
No. 05-370C [Judge Lettow]
PLAINTIFFS' UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Pursuant to Rule 6.1 of the Rules of the United States Court of Federal Claims ("RCFC") plaintiffs, ADRIAN RODRIGUEZ and ALI JAZMIN RODRIGUEZ respectfully request an enlargement of time to and including October 28, 2005 within which to file an opposition to the motion to dismiss or, in the alternative, for summary judgment filed by the defendant THE UNITED STATES. The response is due October 7, 2005. This is the second request for an enlargement of time. Counsel for the defendant, THE UNITED STATES, has represented that THE UNITED STATES does not oppose this request. The requested enlargement of time is necessary because counsel for the plaintiff is currently unavailable due to a family emergency. Plaintiffs' counsel recently registered for electronic filing; however, the motion is a comprehensive motion which requires a great deal of research and drafting to respond to the same.
For the foregoing reasons, it is respectfully requested that the Court grant the unopposed
Case 1:05-cv-00370-CFL
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Filed 10/07/2005
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motion for an enlargement of time within which plaintiffs may respond to defendant's motion to dismiss and/or for summary judgment to and including October 28, 2005. Dated: October 6, 2005 Respectfully submitted,
TERESA TRUCCHI SUPPA, TRUCCHI AND HENEIN, LLP 3055 India Street San Diego, CA 92103 (619) 297-7330 (619) 297-9658 (fax) [email protected]