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

Case 1:08-cv-00196-LAS

Document 8

Filed 07/28/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS

C.R. PITTMAN CONSTRUCTION COMPANY, INC., Plaintiff

v.

No. 08-196C (Senior Judge Smith)

THE UNITED STATES, Defendant

PLAINTIFF'S MOTION FOR ENLARGEMENT OF TIME TO FILE JOINT PRELIMINARY STATUS REPORT

Pursuant to Rules 6.1 and 6(b) of the Rules of the United States Court of Federal Claims ("RCFC"), Plaintiff, C.R. Pittman Construction Company, Inc., respectfully requests, on behalf of the parties, an eleven (11) day enlargement of time, to and including August 8, 2008, to file the Joint Preliminary Status Report. The parties' Joint Preliminary Status Report currently is

due on July 28, 2008. This is the first request for additional time to file the Joint Preliminary Status Report. Additional time is requested for the parties to continue discussions about the course of the case, to discuss plans for motions and discovery, and for Plaintiff to consider certain proposals by Defendant, The United States, on proceedings. Plaintiff's counsel has discussed this request for additional time with Defendant's counsel and Defendant's counsel has no objection. SIGNED this 28th day of July, 2008

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Case 1:08-cv-00196-LAS

Document 8

Filed 07/28/2008

Page 2 of 2

Respectfully submitted: /s/ Gerald A. Melchiode __________________________________________ GERALD A. MELCHIODE, T.A. GALLOWAY, JOHNSON, TOMPKINS, BURR & SMITH One Shell Square 701 Poydras Street, 40th Floor New Orleans, Louisiana 70139 Telephone: (504) 525-6802 Facsimile: (504) 525-2854 Attorney for Petitioner, C.R. Pittman Construction Company, Inc. Of Counsel: WILLIAM J. PERRY JASON J. MARKEY GALLOWAY, JOHNSON, TOMPKINS, BURR & SMITH One Shell Square 701 Poydras Street, 40th Floor New Orleans, Louisiana 70139 Telephone: (504) 525-6802 Facsimile: (504) 525-2854

CERTIFICATE OF SERVICE I hereby certify that on July 28, 2008, I electronically filed the foregoing with the Clerk of Court by using the CM/ECF system, which will send a notice of electronic filing to all participating counsel of record. /s/ Gerald A. Melchiode

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