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

Case 1:03-cv-00626-TCW

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Filed 05/21/2004

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS GULF INSURANCE CO., Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 03-626C (Senior Judge Smith)

DEFENDANT'S MOTION FOR AN ENLARGEMENT OF TIME Pursuant to Rule 6.1 of the Rules of the United States Court of Federal Claims ("RCFC"), defendant, the United States, respectfully requests a 30-day enlargement of time, to and including June 21, 2004, to file our dispositive motion. Our motion is currently due on May 21, 2004. This is our

second request for an enlargement of time for this purpose. We were unable to reach plaintiff's counsel to ascertain his position on this request. The requested enlargement of time is necessary because the undersigned counsel was out of the office unexpectedly due to illness on May 19, 2004 and May 20, 2004. In addition, the

undersigned counsel will be leaving the Department of Justice effective June 1, 2004, and this case will be assigned to a new attorney. We believe that the requested enlargement is

sufficient to allow the newly-assigned attorney to become familiar with the case and to allow us to complete our motion,

Case 1:03-cv-00626-TCW

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Filed 05/21/2004

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coordinate with agency counsel, and finalize the motion for filing. For the foregoing reasons, we respectfully request that the Court grant our motion to enlarge the time within which we may file our dispositive motion by 30 days, to and including June 21, 2004. Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director s/ Kathryn A. Bleecker KATHRYN A. BLEECKER Assistant Director s/ Margaret E. McGhee MARGARET E. McGHEE Attorney Commercial Litigation Branch Civil Division Department of Justice 1100 L Street, N.W. Attn: Classification Unit 8th Floor Washington, DC 20530 Tel. (202) 305-3634 Fax. (202) 514-8640 May 21, 2004 Attorneys for Defendant

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Case 1:03-cv-00626-TCW

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NOTICE OF FILING I hereby certify that on May 21, 2004, a copy of the foregoing "DEFENDANT'S MOTION FOR AN 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. Parties may access this filing through the Court's system.

/s Margaret E. McGhee