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

Case 1:99-cv-00279-SGB

Document 299

Filed 12/10/2007

Page 1 of 3

UNITED STATES COURT OF FEDERAL CLAIMS AMEC CONSTRUCTION MANAGEMENT, INC., f/k/a Morse Diesel International, Inc. Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) ) ) )

Case No. 99-279 and consolidated cases (Judge Braden)

PLAINTIFF'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME Plaintiff respectfully requests, pursuant to Rule 6(a) of the Rules of the Court of Federal Claims ("RCFC"), that the Court grant an unopposed enlargement of time of 9 days from January 2, 2008, to January 11, 2008, for plaintiff to file its reply to defendant's opposition to Plaintiff's Motion for Spoliation Sanctions which is due on December 21, 2007. Plaintiff's counsel and defendant's counsel have discussed this motion, and defendant does not oppose this motion for enlargement of time. The Government's opposition is now due on December 21, 2007. Therefore, plaintiff's reply brief is due on January 2, 2008. In light of the busy holiday schedule, plaintiff requests a 9 day enlargement of time to file its reply. Accordingly, plaintiff respectfully requests that the Court grant this unopposed motion and allow an enlargement of time to and including January 11, 2008, for plaintiff to prepare and file its reply in support of Plaintiff's Motion for Spoliation Sanctions.

Case 1:99-cv-00279-SGB

Document 299

Filed 12/10/2007

Page 2 of 3

Respectfully submitted, s/ James D. Wareham James D. Wareham Attorney of Record for Plaintiff Kirby D. Behre Danielle W. Pierce Paul, Hastings, Janofsky & Walker LLP 875 Fifteenth Street, N.W. Washington, D.C. 20005 Tel: 202-551-1728 Fax: 202-551-0128 December 10, 2007

Case 1:99-cv-00279-SGB

Document 299

Filed 12/10/2007

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that this 10th day of December 2007 I caused a copy of the foregoing Unopposed Motion for Enlargement of Time to be served by electronic mail (via ECF) upon counsel for the Defendant as follows: Dominique Kirchner Senior Trial Counsel Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L Street N.W. Washington, DC 20530 Tracy L. Hilmer Civil Division U.S. Department of Justice 601 D Street, N.W. P.O. Box 261 Ben Franklin Station Washington, DC 20044

s/ Kirby D. Behre Kirby Behre

LEGAL_US_E # 77506719.2