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

Case 1:01-cv-00358-LB

Document 94

Filed 07/16/2008

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS No. 01-358 T Judge Lawrence J. Block JEFFREY T. SCUTERI, Plaintiff, v. THE UNITED STATES, Defendant. JOINT MOTION FOR EXTENSION OF TIME TO FILE STATUS REPORT On July 1, 2008, the Court denied a motion to reconsider its decision in Prati, Fed. Cl. No. 02-60 T [Doc. #95]. Pursuant to the Court's April 16, 2008, and May 19, 2008, orders, the parties are due to file a joint status report in this case on July 16, 2008, regarding the 46 AMCOR cases enumerated in footnote 7 of the Court's Opinion (id. [Doc. #87]) (not including Penni). The parties respectfully request that they be granted one additional week, until July 23, 2008, to file their joint status report. The parties have consulted on a draft joint status report and require one additional week to revise and finalize it. Defendant prepared and provided plaintiff with a draft joint status report on May 15, 2008, and, after the Court's ruling on reconsideration, a substantially similar one again on July 14, 2008. Using the draft, the parties have consulted regarding how best to proceed with the 46 cases enumerated in footnote 7 of the Court's Opinion plus two other related cases still pending before this Court, but have not yet been able to agree on a joint proposal for further proceedings. The parties believe they are close to a final proposal, and can complete

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Case 1:01-cv-00358-LB

Document 94

Filed 07/16/2008

Page 2 of 2

their consultation on the 48 related cases, agree on an approach to recommend to the Court, and file their joint status report within the additional week requested. Defendant's attorney has authorized plaintiff's attorney to sign this joint motion on his behalf. WHEREFORE, the parties respectfully request that they be granted one additional week, until July 23, 2008, to file their joint status report. Respectfully submitted, 7/16/2008 Date s/Bart D. Jeffress by s/ Thomas E. Redding BART D. JEFFRESS Attorney of Record U.S. Department of Justice Tax Division Court of Federal Claims Section Post Office Box 26 Ben Franklin Post Office Washington, D.C. 20044 (202) 307-6496 (202) 514-9440 (fax) NATHAN J. HOCHMAN Assistant Attorney General DAVID GUSTAFSON Chief, Court of Federal Claims Section STEVEN I. FRAHM Assistant Chief, Court of Federal Claims Section 7/16/2008 Date 7/16/2008 Date s/Steven I. Frahm by s/ Thomas E. Redding Of Counsel Attorneys for Defendant s/Thomas E. Redding THOMAS E. REDDING Redding & Associates, P.C. 2914 West T.C. Jester Houston, Texas 77018 (713) 965-9244 (713) 621-5227 (fax) Attorney for Plaintiff