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

Case 1:95-cv-00250-LAS

Document 146

Filed 09/11/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS Filed Electronically: September 11, 2007

1ST HOME LIQUIDATING TRUST, ROGER P. KAVANAGH, JR., EVERETTE E. MILLS, III and WILLIAM E. STONE, Plaintiffs, v. THE UNITED STATES, Defendant.

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No. 95-250C (Senior Judge Loren A. Smith)

PLAINTIFFS' UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Pursuant to Rule 6(b) of the Rules of the United States Court of Federal Claims, Plaintiffs 1st Home Liquidating Trust ("1st Home Trust"), and Everette E. Mills, III and William E. Stone (the "Trustees") (collectively, "Plaintiffs")1, respectfully request an enlargement of time of seven (7) calendar days, to and including September 19, 2007, within which to file a reply to the government's response to Plaintiffs' motion for entry of partial judgment under Rule 54(b) dated August 29, 2007. Plaintiffs' reply is currently due September 12, 2007. This modest enlargement is appropriate and should be granted to afford Plaintiffs adequate time to respond to the government's arguments and to conduct appropriate review of information obtained from additional beneficiaries who have recently contacted the Trustees since Plaintiffs' filing of their amended complaint. Plaintiffs also require this enlargement due to the need for substantial unforeseen work this week on a filing due

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Named plaintiff Roger P. Kavanagh, Jr. is deceased.

Case 1:95-cv-00250-LAS

Document 146

Filed 09/11/2007

Page 2 of 2

in another case on September 12, the day before the current due date for plaintiff's reply in this case, and the need for plaintiff's counsel to leave early September 13 and be absent from the office the following two days for the Jewish New Year holiday. Counsel (David Levitt) for the United States, has represented that the government does not oppose this motion. Therefore, the Court should grant this motion and enlarge the time for plaintiffs' reply to make it due on or before September 19. Respectfully submitted, Dated: September 11, 2007 s/ Jerry Stouck_______ Jerry Stouck Greenberg Traurig, LLP 800 Connecticut Avenue, NW Suite 500 Washington, DC 20006 (202) 331-3173 (202) 261-4751 Counsel for Plaintiffs 1st Home Liquidating Trust, Everette E. Mills, III and William E. Stone Of Counsel: Robert A. Caplen Greenberg Traurig, LLP

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