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

Case 1:07-cv-00867-TCW

Document 23

Filed 07/14/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS AMERICAN ORDNANCE LLC, Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 07-867C (Judge Wheeler)

DEFENDANT'S UNOPPOSED MOTION FR AN ENLARGEMENT OF TIME Pursuant to Rule 7.2(b) of the Rules of the United States Court of Federal Claims ("RCFC"), defendant, United States, respectfully requests an additional two days, to and including July 16, 2008 to file the stipulation of uncontested material facts. This filing is currently due to be filed July 14, 2008. Defendant's counsel has spoken with counsel for the plaintiff who states that he does not oppose this motion. Defendant's counsel requests this brief extension to afford sufficient time to consult with counsel for Army as to which facts are appropriately considered uncontested such that they can be included in a stipulation with plaintiff. Additionally, the extension of time is necessary to accommodate the need for internal review of the proposed stipulation and to coordinate with the plaintiff. Defendant's counsel returned to the office today, having been out of town in trial in Scott Timber Co. v. United States, Fed. Cl. No. 05-708C, all of last week. Upon returning to the office, it was learned that the necessary personnel were, unfortunately, unavailable for discussion to permit a timely filing. For these reasons, defendant respectfully requests that the deadline for the parties' to file a stipulation of uncontested material facts be extended to Wednesday, July 16, 2008.

Case 1:07-cv-00867-TCW

Document 23

Filed 07/14/2008

Page 2 of 3

Respectfully submitted, GREGORY G. KATSAS Acting Assistant Attorney General JEANNE E. DAVIDSON Director s/Reginald T. Blades, Jr. REGINALD T. BLADES, JR. Assistant Director OF COUNSEL: James Mackey Ives Litigation Attorney General Litigation Branch Army Litigation Center 901 N. Stuart Street, Suite 400 Arlington, Virginia 22203 Larry Manecke U.S. Army Sustainment Command Office of Counsel AMSAS-GC Bldg. 390 1 Rock Island Arsenal Rock Island, Illinois 61299-6000 July 14, 2008 s/ Joan M. Stentiford JOAN M. STENTIFORD Trial Attorney Commercial Litigation Branch Civil Division Department of Justice 1100 L Street, N.W. Attn: Classification Unit 8th Floor Washington, D.C. 20530 Telephone: (202) 616-0341 Fax: (202) 514-8624

Attorneys for Defendant

2

Case 1:07-cv-00867-TCW

Document 23

Filed 07/14/2008

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CERTIFICATE OF SERVICE I hereby certify under penalty of perjury that on this 14th day of July, 2008, the foregoing "DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME", 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/ Joan M. Stentiford JOAN M. STENTIFORD