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

Case 1:08-cv-00198-LMB

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS ) BAY PLAZA PROPERTIES, LLC, et al., ) ) Plaintiffs, ) ) v. ) ) UNITED STATES OF AMERICA, ) ) Defendant. ) ________________________________ )

Hon. Lawrence M. Baskir

No. 08-198

UNOPPOSED MOTION FOR ENLARGEMENT OF TIME TO FILE THE PARTIES' JOINT PRELIMINARY STATUS REPORT

Pursuant to Rule 6.1 of the Rules of the Court of Federal Claims ("RCFC"), Defendant hereby respectfully requests an enlargement of two (2) days, or to and including July 16, 2008, for the filing of the parties' Joint Preliminary Status Report ("JPSR"). This is the first request for extension of this deadline. Defendant requires this additional time in order to coordinate its internal position on the matters contained in the JPSR. Defendant apologizes to the Court for the closeness of this request to the current due date of the JPSR, July 14. This situation arose because, on July 11, Defendant provided Plaintiffs with a draft JPSR it believed to have been prepared for this matter. In fact, the draft JPSR sent to Plaintiffs was

Case 1:08-cv-00198-LMB

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prepared for another case. Plaintiffs prepared a JPSR for this matter and provided it to Defendant on the morning of July 14. After receiving the draft JPSR from Plaintiffs the morning of July 14, Defendant only became aware on the afternoon of July 14 that it would be unable to coordinate its internal position on this JPSR prior to the currently-scheduled due date. Counsel for Defendant has contacted Counsel for Plaintiffs who have indicated that Plaintiffs do not oppose this motion for enlargement. WHEREFORE Defendant, with the consent of Plaintiffs, respectfully requests an enlargement of two (2) days, or to and including July 16, 2008, for the filing of the parties' Joint Preliminary Status Report.

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Respectfully submitted this 14th day of July 2008,

RONALD J. TENPAS Assistant Attorney General Environment and Natural Resources Division

s/ Mark T. Romley Mark T. Romley Trial Attorney Natural Resources Section Environment & Natural Resources Division United States Department of Justice P. O. Box 663 Washington, D.C. 20044-0663 Telephone: (202) 305-0458 Fax: (202) 305-0506 Counsel for the Defendant.

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