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

Case 1:00-cv-00428-CCM

Document 96

Filed 10/30/2006

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS

INTERNATIONAL AIR RESPONSE, 22000 South Price Road Chandler, Arizona 85248, Plaintiff, vs. THE UNITED STATES, Defendant.

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Case No. 00-428C

(Assigned to the Honorable Christine O.C. Miller)

Filed October 30, 2006

UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE APPENDIX A SUBMISSIONS Plaintiff/counterdefendant International Air Response moves for an extension of time from October 30, 2006 to November 6, 2006 to file its filings pursuant to paragraphs 14(a), 15 and 16 of Appendix A. Counsel for the Government does not object to this request for an extension. The request is necessitated by two circumstances: (1) IAR made a settlement proposal to the Government some time ago and has tried to hold off on trial preparation and expense as long as possible while awaiting the Government's response, which was expected some time ago but to date has not been provided; and (2) counsel's colleague had a baby last week and has been unavailable in order to help identify the location of certain exhibits and materials. This request should not otherwise prejudice the remaining pretrial schedule.

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1783005.1

Case 1:00-cv-00428-CCM

Document 96

Filed 10/30/2006

Page 2 of 2

Respectfully submitted,

Date: October 30, 2006

By: s/ Randy Papetti Randy Papetti Lewis and Roca LLP 40 North Central Avenue Phoenix, Arizona 85004-4429 602-262-5337 Telephone 602-734-3865 Facsimile Attorney of Record for Plaintiff International Air Response