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

Case 1:07-cv-00828-NBF

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Filed 06/12/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS

LOURDES HYDE, Plaintiff, v. THE UNITED STATES, Defendant.

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No. 07-828C (Judge Firestone)

DEFENDANT'S CONSENT MOTION FOR ENLARGEMENT OF TIME Pursuant to Rule 6(b)(1) of the Rules of the United States Court of Federal Claims ("RCFC"), defendant, the United States, respectfully requests a 21-day enlargement of time, to and including July 3, 2008, within which to file the administrative record in this action. 2008. The record is currently due on June 12,

Defendant has previously requested two enlargements of The undersigned has

time totaling 44-days for this purpose.

contacted plaintiff's counsel, who has stated that plaintiff consents to this motion. This enlargement is requested to allow the parties to determine if resolution of this matter can be achieved through settlement, thereby relieving the parties of the burdens and expenses associated with continuing to litigate this matter. The parties are currently engaged in settlement discussions. these discussions are fruitful, this case may be voluntarily dismissed and the filing of an administrative record would not If

Case 1:07-cv-00828-NBF

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be necessary.

However, we are currently awaiting additional

information that will be the basis for the parities to determine whether the issues raised in this case can be resolved through settlement. We expect that a 21-day extension of time, to and

including July 3, 2008, will result in the most efficient use of the Court's and the parties' resources. We respectfully request

also that the remaining dates on the schedule similarly be extended by 21 days. For the foregoing reasons, defendant respectfully requests that the Court grant this consent motion for an enlargement of time. Respectfully submitted, JEFFREY S. BUCHOLTZ Acting Assistant Attorney General JEANNE E. DAVIDSON Director /s/ Reginald T. Blades, Jr. REGINALD T. BLADES, JR. Assistant Director /s/ David S. Silverbrand DAVID S. SILVERBRAND Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L Street Washington, D.C. 20530 tel: (202) 305-3278 June 12, 2008 Attorneys for Defendant

Case 1:07-cv-00828-NBF

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CERTIFICATE OF SERVICE I hereby certify under penalty of perjury that on this 12th day of June, 2008, a copy of the foregoing consent motion for an 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/ DAVID S. SILVERBRAND