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

Case 1:05-cv-00217-LAS

Document 16

Filed 05/08/2006

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS

ARBITRAJE CASA DE CAMBIO, S.A. DE CV.; et al. Plaintiffs, v. UNITED STATES, Defendant.

) ) ) ) ) Case No. 05-217C Senior Judge Smith

PLAINTIFFS' UNOPPOSED MOTION FOR ENLARGEMENT OF TIME TO OPPOSE DEFENDANT'S MOTION TO DISMISS Plaintiffs respectfully request an enlargement of time of forty-five ( 45) days, to and including June 22, 2006, within which to file their opposition to Defendant's Motion to Dismiss, filed on or about April 10, 2006. Plaintiffs' opposition to Defendant's Motion is currently due May 8, 2006. This is the first requested extension. Counsel for Defendant has consented to the requsted enlargement. Defendant requested, and received, two enlargements of time to respond to Plaintiffs' Amended Complaint. Defendant's first enlargement was for 59 days, and the second was for 45 days. Defendant's Motion raises substantial questions concerning this Court's jurisdiction based on the Contract Disputes Act, sovereign immunity, and the unmistakability doctrine, in addition to questioning the legal sufficiency of Plaintiffs' claims. Based on the issues raised in the Defendant's Motion, and based on the litigation schedule and time commitments of lead counsel in this matter,

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Case 1:05-cv-00217-LAS

Document 16

Filed 05/08/2006

Page 2 of 2

Richard H. Middleton, Jr., Plaintiffs require the additional time requested in order to respond to the Defendant's Motion to Dismiss. WHEREFORE, Plaintiffs respectfully request that this Court enter an order granting them an enlargement of time of forty-five ( 45) days, to and including June 22, 2005, within which to file their opposition to Defendant's Motion to Dismiss.

__s/ Howard G. Slavit_______ Howard G. Slavit, Esq. Saul Ewing LLP 1025 Thomas Jefferson St., N.W. Suite 425 West Washington, D.C. 20007 (202) 295-6600 (202) 295-6700 Fax

__s/ Richard H. Middleton, Jr.__ Richard H. Middleton, Jr., Esq. The Middleton Firm, L.L.C 58 East Broad Street Savannah, GA 31401 (912) 234-1133 Tel. (912) 233-1750 Fax Attorneys for Plaintiffs

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