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

Case 1:08-cv-00230-LMB

Document 10

Filed 09/12/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS ) ) ) ) ) ) ) ) ) ) )

SSC Settlements, LLC, Plaintiff, v. THE UNITED STATES, Defendant.

No. 08-230C (Judge Baskir)

DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME Pursuant to Rule 6(b) of the Rules of the United States Court of Federal Claims, defendant, the United States, respectfully requests a 14day enlargement of time, through and including September 26, 2008, within which the parties may file their joint status report (JSR) as required by the Court's special procedures order. The JSR is currently due on September 12, 2008. This is our first request for an enlargement of time for this purpose. On September 12, 2008, counsel for plaintiff SSC Settlements, LLC (SSC) indicated that SSC is not opposed to this motion. The requested enlargement is necessary because preparation of the JSR and coordination with SSC and agency counsel will require more time than previously anticipated. In particular, Government counsel determined on September 11, 2008 that additional documents may be necessary to

Case 1:08-cv-00230-LMB

Document 10

Filed 09/12/2008

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adequately prepare the portion of the JSR relating to the factual and legal issues, claims, and defenses. In addition, these documents may be relevant to the portion of the JSR describing the grounds for the dispositive motion that we intend to file. Government counsel has requested those documents but will be unable to review the documents and coordinate the drafting of the JSR on or before the current due date. For these reasons, we respectfully request that the Court grant a 14-day extension of time, through and including September 26, 2008, within which the parties may file the JSR.

Respectfully submitted, GREGORY G. KATSAS Acting Assistant Attorney General JEANNE E. DAVIDSON Director s/ Martin F. Hockey, Jr. by Deborah A. Bynum MARTIN F. HOCKEY, Jr. Assistant Director

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Case 1:08-cv-00230-LMB

Document 10

Filed 09/12/2008

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s/ Michael J. Dierberg MICHAEL J. DIERBERG Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit, 8th Fl. 1100 L St. NW Washington, DC 20530 September 12, 2008 Attorneys for Defendant

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