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

Case 1:02-cv-01624-FMA

Document 17

Filed 06/09/2003

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS WASHINGTON INTERNATIONAL INSURANCE COMPANY, Plaintiff, v. UNITED STATES OF AMERICA, Defendant. ) ) ) ) ) ) ) ) ) )

No. 02-1624C (Judge Allegra)

DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME TO FILE REPLY IN SUPPORT OF DEFENDANT'S MOTION TO DISMISS Defendant, the United States, respectfully files this Motion For Enlargement Of Time To File A Reply In Support Of Our Motion To Dismiss. The reply brief is presently due on or before We request 7 days, up to and including, We consulted the

June 10, 2003.

June 17, 2003, in which to file a reply brief.

attorney for the plaintiff who states that the plaintiff does not oppose this request for enlargement of time, which is our first request for this purpose. After the plaintiff filed its opposition, the undersigned has worked on other assignments. On June 4, 2003, the

undersigned presented oral argument in Caspary v. Department of Health and Humans Services, (Fed. Cir. 02-3275). The undersigned

is also responsible for filing a motion for judgment upon the

Case 1:02-cv-01624-FMA

Document 17

Filed 06/09/2003

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administrative record in Sutton v. United States, (Fed. Cl. 0390C) on June 6, 2003, and participating in status conference on June 16, 2003, in A.K. Suda, Inc. v. United States, (Fed. Cl. 00-172C), a case recently transferred to the undersigned. For these reasons, we respectfully request that the Court grant our motion for enlargement of time and that time for filing our reply brief be extended until June 17, 2003. Respectfully submitted, ROBERT D. McCALLUM, Jr. Assistant Attorney General DAVID M. COHEN Director s/ Donald E. Kinner DONALD E. KINNER Assistant Director Of Counsel: MAJOR GRAEME S. HENDERSON Attorney Department of the Air Force AFSLA/JACN 1501 Wilson Boulevard, Suite 606 Arlington, VA 22209-2403 s/ Christian J. Moran CHRISTIAN J. MORAN Trial Attorney Commercial Litigation Branch Civil Division United States Department of Justice Attention: Classification Unit 8th Floor 1l00 L Street, NW Washington, D.C. 20530 Telephone (202) 307-6289 Facsimile (202) 514-7969 Attorneys for Defendant Date: June 9, 2003

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