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

Case 1:92-cv-00550-MCW

Document 128

Filed 10/10/2006

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS __________________________________________ ) NORTHEAST SAVINGS, F.A. ) ) Plaintiff, ) ) v. ) ) UNITED STATES OF AMERICA, ) ) Defendant. ) ) __________________________________________)

Civil Action No. 92-550C Judge Coster Williams

UNOPPOSED MOTION TO EXTEND DEADLINE FOR EXCHANGING TRIAL SCHEDULES Plaintiff, Northeast Savings, F.A., respectfully moves for an order extending the deadline for exchanging trial schedules. Counsel for defendant, the United States, has informed counsel for Northeast that the United States does not oppose this motion. By order of August 1, 2006, the Court instructed the parties to exchange their trial schedules by October 10, 2006. Northeast proposes instead that each party provide its trial schedule to the other party one week before it begins putting on its case. This procedure has been used successfully in other Winstar-related trials. For example, if Northeast will begin putting on its case on October 23 and the United States will begin putting on its case on October 30, under this proposal Northeast would provide its trial schedule to the United States by October 16 and the United States would provide its trial schedule to Northeast by October 23.

Case 1:92-cv-00550-MCW

Document 128

Filed 10/10/2006

Page 2 of 2

Respectfully submitted, /s/ Charles J. Cooper ___________________________________ Charles J. Cooper COOPER & KIRK, PLLC 555 Eleventh Street, N.W., Suite 750 Washington, D.C. 20004 (202) 220-9600 (202) 220-9601 (fax) Counsel of Record for Plaintiff Northeast Savings, F.A. Of Counsel: Michael W. Kirk Vincent J. Colatriano David H. Thompson David Lehn COOPER & KIRK, PLLC 555 Eleventh Street, N.W., Suite 750 Washington, D.C. 20004 (202) 220-9600 (202) 220-9601 (fax)

October 10, 2006

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