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

Case 1:08-cv-00114-LMB

Document 9

Filed 06/03/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS ________________________________ ) HUBBARD PROPERTIES, INC., and ) JAMES L. HUBBARD ) ) Plaintiff, ) ) v. ) No. 08-114C ) (Judge Baskir) THE UNITED STATES, ) ) Defendant. ) ________________________________ ) CONSENT MOTION FOR AN ENALRGEMENT OF TIME TO FILE THE JOINT PRELIMINARY STATUS REPORT Defendant respectfully requests an enlargement of 11 days, to and including June 20, 2008, in which to file the Joint Preliminary Status Report ("JPSR"). The JPSR is currently due on June 9, 2008. This is defendant's first request for an enlargement of time for this purpose. Defendant has contacted plaintiff's counsel, who states that plaintiff consents to this motion. Defendant seeks this enlargement to allow the parties sufficient time to complete the JPSR. The parties have begun drafting the JPSR but require more time to finish a draft and obtain required supervisory review. In particular, the parties need to complete their analysis of issues raised by the case, to consider and discuss the possibility of alternative dispute

Case 1:08-cv-00114-LMB

Document 9

Filed 06/03/2008

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resolution, and to negotiate an appropriate discovery plan. An enlargement of 11 days should allow the parties sufficient time to complete the JPSR. For these reasons, defendant respectfully requests that the Court grant its motion for an enlargement of time. Respectfully submitted, GREGORY G. KATSAS Acting Assistant Attorney General JEANNE E. DAVIDSON Director s/ Donald E. Kinner DONALD E. KINNER Assistant Director s/ Sean B. McNamara SEAN B. McNAMARA Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit, 8th Floor 1100 L St., NW Washington, DC 20005 Tele: (202) 305-7573 Fax: (202) 514-8624 Dated: June 3, 2008 Attorneys for Defendant

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Case 1:08-cv-00114-LMB

Document 9

Filed 06/03/2008

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CERTIFICATE OF FILING I hereby certify that on June 3, 2008, a copy of the foregoing "CONSENT MOTION FOR AN ENALRGEMENT OF TIME TO FILE THE JOINT PRELIMINARY STATUS REPORT" was filed electronically. I understand that notice of this filing will be sent to all parties by operation of the Court's electronic filing system. Parties may access this filing through the Court's system.

s/ Sean B. McNamara SEAN B. McNAMARA