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

Case 1:03-cv-00288-EJD

Document 44

Filed 11/27/2006

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS CHEVRON U.S.A., INC., And TEXACO INC., And TEXACO DOWNSTREAM LLC, Plaintiffs, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

No. 03-288C (Chief Judge Damich)

PLAINTIFFS' UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Plaintiffs, Chevron U.S.A., Inc., Texaco Inc. and Texaco Downstream LLC (collectively "Chevron"), respectfully request an enlargement of time of seven days, to and including December 7, 2006, for the parties to file the Joint Status Report that currently is due on November 30, 2007. This is Chevron's first request for an enlargement of time for this purpose, and Defendant does not oppose this motion. Chevron seeks an enlargement of time because counsel of record for Chevron unexpectedly is required to be out of the office for two days this week to attend a funeral. Counsel's absence from the office will not permit him to consult fully with Chevron and the government concerning the joint status report and to draft and submit the report together with the government. The additional time also is needed to fully address the Court's recent inquiry concerning discovery in this case while other similar cases are pending on appeal.

Case 1:03-cv-00288-EJD

Document 44

Filed 11/27/2006

Page 2 of 2

For the foregoing reasons, Chevron respectfully requests that its motion for an enlargement of time be granted.

Respectfully submitted, s/ J. Keith Burt J. Keith Burt Mayer, Brown, Rowe & Maw, LLP 1909 K Street, N.W. Washington, D.C. 20006 (202) 263-3208 (Phone) (202) 263-5308 (Fax) Attorneys for Plaintiffs, Chevron U.S.A., Inc., Texaco Inc., and Texaco Downstream LLC Dated: November 27, 2006

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