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

Case 1:01-cv-00047-EGB

Document 175

Filed 04/02/2007

Page 1 of 2

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 April 2, 2007 to April 12, 2007, for defendant to prepare and file its response to plaintiff Lindsey Bledsoe's motion for partial summary judgment in this case. Defendant's response to Mr. Bledsoe's motion is

due April 2, 2007, the Court having previously granted three unopposed motions for enlargement of time, for a total of 60 days. Defendant's counsel informed plaintiffs' counsel, Alan

Banov, of this motion, and is authorized to state that plaintiffs do not oppose defendant's motion for enlargement of time. Defendant's counsel has completed drafting the Government's cross-motion and opposition to plaintiff Lindsey Bledsoe's motion, but requires additional time for its review by attorneys at the Bureau of Prisons and Department of Justice. In addition,

defendant's cross-motion and opposition will be accompanied by a lengthy appendix, and defendant also requires this enlargement of time to scan the appendix electronically and prepare it for an

Case 1:01-cv-00047-EGB

Document 175

Filed 04/02/2007

Page 2 of 2

electronic filing.

Therefore, defendant requires an additional

10 days to prepare and file its response to plaintiff Lindsey Bledsoe's motion for partial summary judgment. Accordingly, defendant respectfully requests that the Court grant this unopposed motion for a 10-day enlargement of time to April 12, 2007, for the Government to prepare and file defendant's response to plaintiff Lindsey Bledsoe's motion for partial 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 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) 307-0290 Attorneys for Defendant Of Counsel: ERIKA TURNER Bureau of Prisons April 2, 2007