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

Case 1:01-cv-00047-EGB

Document 185

Filed 06/29/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS JOSE L. ACEBAL, et al., Plaintiffs, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 01-47C (Senior Judge Bruggink)

DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME Defendant respectfully requests, pursuant to Rule 6(a) of the Rules of the Court of Federal Claims ("RCFC"), that the Court grant an enlargement of time of 10 days from June 29, 2007 to July 9, 2007, for defendant to prepare and file its reply brief to plaintiff Lindsey Bledsoe's opposition to defendant's motion for summary judgment in this case. Defendant's reply to Mr.

Bledsoe's opposition is due June 29, 2007, the Court having granted one unopposed motion for a 17-day enlargement of time. Defendant's counsel informed plaintiffs' counsel of this motion, and is authorized to state that plaintiffs do not oppose defendant's motion for enlargement of time. Defendant's counsel has been preparing the Government's reply brief, but requires additional time to complete preparation of the brief and for its review by attorneys at the Bureau of Prisons and Department of Justice. Defendant's reply brief will

be accompanied by an affidavit and additional documents regarding the Government's payment of overtime to Mr. Bledsoe, and defendant also requires this enlargement of time to complete the

Case 1:01-cv-00047-EGB

Document 185

Filed 06/29/2007

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affidavit.

Further, defendant's counsel among other things had 1) the Government's brief in

to prepare and file the following:

L-3 Communications v. United States, Fed. Cl. No. 06-396 (filed June 5, 2007); and 2) the Government's brief in Sakar Int'l, Inc. v. United States, Fed. Cir. No. 2007-1173 (filed June 26, 2007). Therefore, defendant requires an additional 10 days to complete and file its reply brief to plaintiff Lindsey Bledsoe's opposition to defendant's motion for summary judgment. Accordingly, defendant respectfully requests that the Court grant this unopposed motion for a 10-day enlargement of time to July 9, 2007, for the Government to complete and file its reply brief to plaintiff Lindsey Bledsoe's opposition to defendant's motion for summary judgment in this case. Respectfully submitted, PETER D. KEISLER Assistant Attorney General JEANNE E. DAVIDSON Director

s/Kathryn A. Bleecker KATHRYN A. BLEECKER Assistant Director

Case 1:01-cv-00047-EGB

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Filed 06/29/2007

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s/Domenique Kirchner DOMENIQUE KIRCHNER Senior Trial Counsel Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L Street N.W. Washington, D.C. 20530 Tele: (202) 307-1111 Attorneys for Defendant Of Counsel: ERIKA TURNER Bureau of Prisons June 29, 2007