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

Case 1:07-cv-00232-EJD

Document 14

Filed 04/28/2008

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS ) ) ) ) ) ) ) ) ) ) )

CHRISTOPHER J. GRUSH Plaintiff, v. UNITED STATES OF AMERICA, Defendant.

No. 07-232C (Chief Judge Edward J. Damich)

DEFENDANT'S UNOPPOSED MOTION FOR EXTENSION OF TIME Pursuant to Rule 6(b) of the Rules of the United States Court of Federal Claims, defendant, the United States, respectfully requests an enlargement of time of four days, through and including May 2, 2008, within which the parties may file a joint status report. The joint status report is currently due on April 28, 2008. This is our first request for an enlargement of time for this purpose. Counsel for Mr. Grush has indicated that Mr. Grush is not opposed to this motion. This request for an enlargement of time is necessary because Government counsel assigned to this case, Shalom Brilliant, has been out of the office from April 21 through April 28, 2008. Although the Government previously anticipated that the JSR could be drafted and filed in Mr. Brilliant's absence, on April 28, 2008 it became apparent that certain issues regarding the JSR may not be adequately resolved in Mr. Shalom's absence. For these reasons, we respectfully request an extension of time of four days, through and including May 2, 2008, within which to file the joint status report.

Case 1:07-cv-00232-EJD

Document 14

Filed 04/28/2008

Page 2 of 2

Respectfully submitted, JEFFREY S. BUCHOLTZ Acting Assistant Attorney General s/ Todd M. Hughes TODD M. HUGHES Deputy Director s/ Michael J. Dierberg for Shalom Brilliant SHALOM BRILLIANT Senior Trial Counsel Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 1100 L Street, N.W. Washington, D.C. 20530 Washington, D.C. 20036 Tel: (202) 616-8275 Fax: (202) 305-7643 OF COUNSEL: Michael J. Dierberg William Rayel Trial Attorneys Commercial Litigation Branch Civil Division Department of Justice Attorneys for Defendant Dated: April 28, 2008

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