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

Case 1:00-cv-00644-NBF

Document 201

Filed 06/13/2008

Page 1 of 4

IN THE UNITED STATES COURT OF FEDERAL CLAIMS

WILLIAM A. CLARK, JAMES P. DAVERN, ROBERT E.FREEBURG, WILLIE R. JOHNSON, ROBERT A. MUSTIN, JOHN DOES 1 through 4, and JANE DOES 1 through 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 unopposed motion for an enlargement of time of two (2) business days, up to and including June 17, 2008, within which to file their next joint status report. The parties had previously sought an extension until June 13, 2008. As expected, negotiations have progressed to the point where the parties are in a position to provide a report to the Court. Unfortunately, the parties will not be able to finalize and submit such a report today due to the widespread power failures in the City today. This is the second request for an enlargement of time to file this joint status report. Defendant has authorized Plaintiffs to file this request on behalf of both parties. For the foregoing reasons, the parties respectfully request that the Court grant this request for an enlargement of time of two (2) business days in which to file a Joint Status

Case 1:00-cv-00644-NBF

Document 201

Filed 06/13/2008

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Report.

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Case 1:00-cv-00644-NBF

Document 201

Filed 06/13/2008

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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: June 13, 2008

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Case 1:00-cv-00644-NBF

Document 201

Filed 06/13/2008

Page 4 of 4

CERTIFICATE OF SERVICE

I hereby certify that a copy of the foregoing "Plaintiffs' Unopposed 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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