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

Case 1:07-cv-00884-LJB

Document 11

Filed 03/24/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS SOUTHEAST RESTORATION, INC., Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 07-884C (Judge Bush)

UNOPPOSED MOTION FOR AN EXTENSION OF TIME FOR STAY OF PROCEEDINGS AND REMAND On January 8, 2008, the Court granted the parties' motion to stay the proceedings in this case and remand the matter to the agency contracting officer for a final decision. The Court further directed that the parties file a joint status report on or before April 4, 2008, concerning the status of proceedings. The Department of Veterans Affairs (VA) attorney previously assigned to this case is on indefinite sick leave and the matter has been re-assigned to another lawyer at the VA Office of General Counsel. Additionally, the contracting officer needs additional time to prepare her final decision. For these reasons, the Government respectfully requests that the Court grant an extension of 31 days, to and including May 5, 2008, for the contracting officer to render her final decision. The Government also proposes that the parties file a joint status report informing the Court of the status of the case by Friday, May 9, 2008. Counsel for Southeast Restoration, Inc., does not oppose our request. Respectfully submitted, JEFFREY S. BUCHOLTZ Acting Assistant Attorney General

Case 1:07-cv-00884-LJB

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Filed 03/24/2008

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JEANNE E. DAVIDSON Director s/ Steven J. Gillingham STEVEN J. GILLINGHAM Assistant Director s/ Armando A. Rodriguez-Feo ARMANDO A. RODRIGUEZ-FEO Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L St., NW Washington, D.C. 20530 Tel: (202) 307-3390 Fax: (202) 514-8624 Attorneys for Defendant March 24, 2008

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Case 1:07-cv-00884-LJB

Document 11

Filed 03/24/2008

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CERTIFICATE OF FILING I hereby certify that on this 24th day of March, 2008, a copy of the foregoing "UNOPPOSED MOTION FOR AN EXTENSION OF TIME FOR STAY OF PROCEEDINGS AND REMAND" 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. The parties may access this filing through the Court's system.

s/ Armando A. Rodriguez-Feo