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

Case 1:90-cv-00162-LJB

Document 676

Filed 02/28/2008

Page 1 of 3

IN THE UNITED STATES COURT OF FEDERAL CLAIMS

STEPHEN ADAMS, et al., Plaintiffs, v. UNITED STATES OF AMERICA, Defendant.

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Case No. 90-162-C and Consolidated Cases (Judge Lynn J. Bush)

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PLAINTIFFS' UNOPPOSED MOTION FOR ENLARGEMENT OF TIME Pursuant to Rule 6(b) of the Rules of the United States Court of Federal Claims ("RCFC"), plaintiffs respectfully request a five day enlargement of time within which to file the parties' Joint Status Report ("JSR"). The JSR is currently due on February 29, 2008. The extension would bring the date for filing the JSR to March 5, 2008. This is plaintiffs' first request for an enlargement of time for this purpose. The undersigned counsel spoke with counsel for defendant on February 28, 2008, and counsel indicated that he is not opposed to this motion. The basis for the request is that plaintiffs' counsel, Jules Bernstein and Edgar James, are out of town this week and are not available to discuss the content of the Joint Status Report. The parties need additional time to prepare the JSR and resolve outstanding issues. For the foregoing reason, plaintiffs respectfully request that the Court grant the instant motion for a five day enlargement of time.

Case 1:90-cv-00162-LJB

Document 676

Filed 02/28/2008

Page 2 of 3

Respectfully submitted,

OF COUNSEL: Linda Lipsett Edgar James James & Hoffman 1101 17th Street, N.W. Suite 510 Washington, D.C. 20036 (202) 496-0500

s/Jules Bernstein Jules Bernstein (Counsel of Record) Bernstein & Lipsett, P.C. 1920 L Street, N.W. Suite 303 Washington, D.C. 20036 (202) 296-1798

Attorneys for Plaintiffs

Dated: February 28, 2008

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Case 1:90-cv-00162-LJB

Document 676

Filed 02/28/2008

Page 3 of 3

CERTIFICATE OF FILING I hereby certify under penalty of perjury that on this 28th day of February 2008, a copy of the foregoing "MOTION FOR ENLARGEMENT OF TIME" 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/Jules Bernstein