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

Case 1:04-cv-00718-ECH

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Filed 08/30/2004

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS CW GOVERNMENT TRAVEL, INC., Plaintiff, v. UNITED STATES, Defendant. ) ) ) ) ) No. 04-718C ) (Judge Hewitt) ) ) )

DEFENDANT'S MOTION FOR AN ENLARGEMENT OF TIME Pursuant to Rule 6(b), defendant respectfully requests an enlargement of time of 14 days, to and including September 21, 2004, within which to file a reply to plaintiff's response in opposition to our motion to dismiss or, in the alternative, motion for summary judgment. filing on September 7, 2004. Our reply is currently due for Plaintiff's counsel has represented

that he consents to a one-week enlargement only. Plaintiff filed its response on August 23, 2004. Because of

the press of other business, defendant's counsel was unable, and will be unable, to devote sufficient time to review CW's opposition and draft our reply brief by September 7. Specifically, on August 24, 2004, defendant's counsel filed a motion for reconsideration in Englewood Terrace Ltd. Partnership v. United States, Fed. Cl. No. 03-2209C. Moreover, defendant's

counsel was preparing for, and conducting oral argument upon, plaintiff's motion for summary judgment in Godwin v. United States, Fed. Cl. No. 98-167C, argued on August 26, 2004. In

addition, defendant's counsel was preparing respondent's brief in

Case 1:04-cv-00718-ECH

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Bannum, Inc. v. United States, Fed. Cir. No. 04-5008, filed on August 26, 2004. Finally, defendant's counsel must prepare respondent-appellee's brief in Pamela J. Sharp v. Principi, Fed. Cir. No. 04-7111, due to be filed on September 8, 2004. Accordingly, defendant's counsel needs additional time to review CW's brief and prepare our reply. For the foregoing reasons, defendant respectfully requests the Court to grant an enlargement of time, to and including July 26, 2004, within which to file a reply in support of our motion to dismiss, or, in the alternative, motion for summary judgment. Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director s/William Ryan for James M. Kinsella JAMES M. KINSELLA Deputy Director

s/Lisa B. Donis LISA B. DONIS Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor, 1100 L Street, N.W. Washington, D.C. 20530 Tele: (202) 305-7561 Attorneys for Defendant AUGUST 30, 2004

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Case 1:04-cv-00718-ECH

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CERTIFICATE OF FILING I hereby certify that on August 30, 2004, a copy of foregoing "Motion for Enlargement of Time" 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. system. Parties may access this filing through the Court's

s/Lisa B. Donis LISA B. DONIS

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