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

Case 1:00-cv-00644-NBF

Document 199

Filed 06/03/2008

Page 1 of 3

IN THE UNITED STATES COURT OF FEDERAL CLAIMS

WILLIAM A. CLARK, individually and on behalf of all others similarly situated, Plaintiff, v. THE UNITED STATES, Defendant.

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No. 00-644 (Judge Firestone)

JOINT MOTION FOR AN ENLARGEMENT OF TIME TO SUBMIT A JOINT STATUS REPORT Pursuant to Rule 6(b) and 6.1 of the Rules of the United States Court of Federal Claims ("RCFC"), the United States, upon behalf of the parties, respectfully requests an enlargement of time of nine days, to and including June 13, 2008, for the parties to submit a joint status report which details the parties efforts to resolve any remaining discovery issues so that a schedule for future proceedings to resolve this case can be proposed. Pursuant to the Court's May 21, 2008 order, the parties joint status report is now due on June 4, 2008. This is our first request for an enlargement of time for this purpose. Counsel for defendant has discussed this motion with plaintiffs' counsel, and plaintiffs support this request. A brief enlargement of time is necessary for the parties to complete their discussions with representatives from the state guard organizations and resolve the remaining issues concerning the list of agencies and custodians to be searched for information and the terms to be applied in those searches. The parties believe that the additional time sought in this motion will enable the parties to better inform the Court regarding the issues set forth in the Court's May 21, 2008 order. For the foregoing reasons, defendant, upon behalf of the parties, respectfully requests that the Court grant this request for an enlargement of time of nine days, until June 13, 2008, in

Case 1:00-cv-00644-NBF

Document 199

Filed 06/03/2008

Page 2 of 3

which the parties can file their joint status report detailing the parties efforts to resolve the remaining discovery issues so that a schedule for future proceedings to resolve this case can be proposed. Respectfully submitted, GREGORY G. KATSAS Acting Assistant Attorney General JEANNE E. DAVIDSON Director s/ Bryant G. Snee BRYANT G. SNEE Deputy Director OF COUNSEL: MAJOR JERRETT DUNLAP CAPTAIN PATRICK GRANT United States Army Litigation Division Arlington, VA 22203-1837 LT COL BRIAN ROOU United States Air Force General Litigation Division MAXIMINO GONZALEZ National Guard Bureau Office of Chief Counsel Attorneys for Defendant June 3, 2008 s/ Douglas K. Mickle DOUGLAS K. MICKLE Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit, 8th Floor 1100 L Street, N.W. Washington, D.C. 20530 Tel. (202) 307-0383 Fax (202) 353-7988

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Case 1:00-cv-00644-NBF

Document 199

Filed 06/03/2008

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify under penalty of perjury that on June 3, 2008, a copy of the foregoing "JOINT MOTION FOR AN ENLARGEMENT OF TIME TO SUBMIT A JOINT STATUS REPORT" was filed electronically. I understand that notice of this filing will be sent to all parties by operation of the Court's electronic filing system. Parties may access this filing through the Court's system.

s/Douglas K. Mickle Douglas K. Mickle