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

Case 1:00-cv-00644-NBF

Document 190

Filed 04/18/2008

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 unopposed motion for an enlargement of time of ten business days, up to and including May 1, 2008, within which to file their next joint status report. As explained in the last Joint Status Report filed March 28, 2008, the parties have been working to resolve the remaining document production issues, so Plaintiffs can complete preparation for taking deposition discovery. Since the filing of that report, the parties have made progress on the outstanding issues, but some categories of documents remain to be produced. Government counsel believes that a ten business day extension will allow them to locate and provide these remaining documents, leaving fewer, if any, issues for this Court to consider in the subsequent Joint Status Report.

Case 1:00-cv-00644-NBF

Document 190

Filed 04/18/2008

Page 2 of 3

This is the first request for an enlargement 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 until May 1, 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: April 18, 2008

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Case 1:00-cv-00644-NBF

Document 190

Filed 04/18/2008

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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