Free Motion for Extension of Time - District Court of Federal Claims - federal

Case 1:03-cv-01216-JPW

Document 12

Filed 09/09/2003

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS PLACID HOLDING COMPANY, Plaintiff, vs. THE UNITED STATES, Defendant ) ) ) ) ) ) ) )

No. 03-1216C (Judge Wiese)

PLAINTIFF'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Pursuant to Rule 6.1 of the Rules of the United States Court of Federal Claims, Plaintiff Placid Holding Company ("Placid") respectfully requests an enlargement of time of ten days, to and including September 25, 2003, within which to file its Opposition to Defendant's Motion for Partial Summary Judgment and Cross-Motion for Partial Summary Judgment. Placid's Opposition currently is due on September 15, 2003, and this is Placid's first request for an enlargement of time for this purpose. Defendant does not oppose this request. The requested enlargement of time is needed to allow counsel for Placid both to respond fully to Defendant's summary judgment motion and prepare and incorporate in the same submission Placid's own cross- motion for summary judgment. Counsel for Placid believes that proceeding in this manner will be most efficient for the Court and the parties, as it will allow the parties to file briefs addressing the same issues in combined filings on a one-track briefing and argument schedule. Placid also seeks the additional time to prepare its opposition and crossmotion because of the complexity of the issues raised in Defendant's motion and the need to address and respond to the extensive documentary materials Defendant submitted with its motion.

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Case 1:03-cv-01216-JPW

Document 12

Filed 09/09/2003

Page 2 of 2

For these reasons, Placid respectfully requests that its motion be granted. Respectfully submitted,

s/ J. Keith Burt J. Keith Burt Mayer, Brown, Rowe & Maw LLP 1909 K Street, N.W. Washington, D.C. 20006 (202) 263-3208 (Phone) (202) 263-5208 (Fax) Counsel for Plaintiff Placid Holding Company September 9, 2003

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