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

Case 1:00-cv-00644-NBF

Document 207

Filed 08/12/2008

Page 1 of 3

IN THE UNITED STATES COURT OF FEDERAL CLAIMS

WILLIAM A. CLARK, JAMES P. DAVERN, ROBERT E.FREEBURG, WILLIE R. JOHNSON, ROBERT A. MUSTIN, CAROL RISSER, JOHN DOES 1 through 4, and JANE DOES 2 and 3, individually, and on behalf of all other similarly situated , Plaintiffs, v. THE UNITED STATES, Defendant

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No. 00-644 (Judge Firestone)

JOINT MOTION FOR AN ENLARGEMENT OF TIME TO FILE JOINT STATUS REPORT

Pursuant to Rule 6.1 of the Rules of the Court of Federal Claims, the parties respectfully submit this joint motion for an enlargement of time of seven business days, up to and including August 22, 2008, within which to file their next joint status report. In the last joint status report, filed June 17, the parties explained their progress towards accomplishing the tasks set out in the Court's May 21 Order. The parties continue to work towards completing the tasks set out in this Court's Order, but have not yet been able to complete the process due to absences and other case commitments. In particular, due to vacations and other absences, government counsel has had difficulty contacting all of the key custodians and believes an additional extension will enable the completion of

Case 1:00-cv-00644-NBF

Document 207

Filed 08/12/2008

Page 2 of 3

that process. The parties therefore request an extension in to allow time to work towards completing these tasks and to determine any remaining issues for the Court. This is the second request for an extension of time to file this Joint Status Report. The government's counsel has authorized plaintiffs' counsel to submit this joint request for an enlargement. For the foregoing reasons, the parties respectfully request that the Court grant this request for an enlargement of time of seven business days, up to and including August 22, 2008 in which to file a Joint Status Report. Respectfully submitted,

Richard T. Dorman CUNNINGHAM, BOUNDS, VANCE, CROWDER, and BROWN, LLC 1601 Dauphin Street Mobile, Alabama 36660 Tel: (334) 471-6191 Fax: (334) 479-1031 Charles J. Cooper David Thompson COOPER & KIRK, P.L.L.C. 555 11th Street, N.W., Suite 750 Washington, DC 20005 Tel: (202) 220-9600 Fax: (202) 220-9601

/s/ Helen K. Michael Helen K. Michael HOWREY SIMON ARNOLD & WHITE, LLP 1299 Pennsylvania Avenue, N.W. Washington, D.C. 20004 Tel: (202) 783-0800 Fax: (202) 383-6610

Counsel for Plaintiffs Dated: August 12, 2008

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Case 1:00-cv-00644-NBF

Document 207

Filed 08/12/2008

Page 3 of 3

CERTIFICATE OF SERVICE

I hereby certify that a copy of the foregoing "Joint Motion for an Enlargement of Time to File Joint Status Report" was filed electronically. I understand that notice of this filing will be sent to all parties by the operation of the Court's electronic filing system. Parties may access this filing through the Court's system.

/s Helen K. Michael Helen K. Michael

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