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

Case 1:98-cv-00897-FMA

Document 151

Filed 04/08/2005

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS ) ) ) ) ) ) ) ) ) ) )

ROBERT BRACE, Plaintiff, v. UNITED STATES, Defendant.

Civil Action No. 98-897 L Hon. Francis M. Allegra

PLAINTIFFS' UNOPPOSED MOTION FOR ENLARGEMENT OF TIME Plaintiff moves for a seven-day enlargement of time to and including April 19, 2005 for the filing deadline for Post-Trial Briefs. Accordingly, Plaintiff requests that the filing deadline for Reply Briefs, currently scheduled for May 12, 2005, be moved to May 19, 2005. Plaintiffs do not request that Closing Argument, currently scheduled for May 31, 2005, be rescheduled. Plaintiff's motion is based on the following: Plaintiff's Post-Trial brief is now due on April 12, 2005. However, due to other case commitments, Plaintiff's counsel needs additional time to review the trial transcript, adequately and thoroughly prepare the brief, and consult with the client regarding the brief. Plaintiff has not requested or been previously given an enlargement of time upon which to file its Post-Trial Brief. Defendant's counsel has agreed to Plaintiff's request for an extension, and does not oppose this motion. For the foregoing reasons, Plaintiff respectfully requests that this Court grant a seven-day enlargement of time to and including April 19, 2005 for the filing deadline for Post-Trial Briefs, and a corresponding enlargement of time to and including May 19, 2005 for the filing deadline for Reply Briefs.

Case 1:98-cv-00897-FMA

Document 151

Filed 04/08/2005

Page 2 of 2

Respectfully submitted,

___s/ Nancie G. Marzulla________ Nancie G. Marzulla Roger J. Marzulla DEFENDERS OF PROPERTY RIGHTS 1350 Connecticut Avenue NW, Suite 410 Washington, DC 20036 202-822-6770 202-822-6774 (facsimile) Counsel for Plaintiffs Dated: April 8, 2005

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