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

Case 1:07-cv-00828-NBF

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Filed 04/29/2008

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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 30-day enlargement of time, to and including May 30, 2008, within which to file the administrative record in this action. 2008. The record is currently due on April 30,

Defendant has not previously requested an enlargement of The undersigned has contacted

time for this purpose.

plaintiff's counsel, who has stated that plaintiff consents to this motion. This enlargement is requested in order 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 which will be the basis for the parities to determine whether the issues raised in this case can be resolved through settlement. Thus, we expect that a 30-day extension of

time, to and including May 30, 2008, will result in the most efficient use of the Court's and the parties' resources. The

remaining dates on the schedule should similarly be extended by 30 days. For the foregoing reasons, defendant respectfully requests that the Court grant this 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 fax: (202) 353-7988 April 29, 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 29th day of April, 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