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

Case 1:07-cv-00817-TCW

Document 17

Filed 12/05/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS GREAT LAKES DREDGE & DOCK CO., LLC, Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) )

No. 07-817 (Judge Wheeler)

DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Pursuant to Rule 6.1 of the Rules of the Court of Federal Claims, defendant respectfully requests a two day enlargement of time, through and including December 7, 2007, to file the administrative record. The administrative record is currently due to be filed on December 5, 2007. This is defendant's first request for an enlargement of time for this purpose. Defendant's counsel has spoken with Daniel Sauls, counsel for Great Lakes Dredge & Dock Company LLC ("GLDD"), who stated that he does not oppose this motion. In support of this motion, defendant states that the parties have engaged in settlement discussions in an attempt to resolve this matter amicably. Defendant has received a settlement proposal from GLDD which defendant's counsel has submitted to the authorized representative of the Attorney General for a decision. The requested enlargement of time will conserve the resources of the Court and the parties while the settlement decision is pending. Accordingly, defendant requests a two day enlargement of time to file the administrative record. Respectfully submitted, JEFFREY S. BUCHOLTZ Acting Assistant Attorney General

Case 1:07-cv-00817-TCW

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Filed 12/05/2007

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JEANNE E. DAVIDSON Director

s/Harold D. Lester, Jr. HAROLD D. LESTER, JR. Assistant Director

s/Michael N. O'Connell MICHAEL N. O'CONNELL Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L Street Washington, D.C. 20530 tel: (202) 353-4175 fax: (202) 307-0972 December 5, 2007 Attorneys for Defendant

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Case 1:07-cv-00817-TCW

Document 17

Filed 12/05/2007

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CERTIFICATE OF FILING I hereby certify that on December 5, 2007 a copy of foregoing "UNOPPOSED 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/Michael O'Connell

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