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

Case 1:07-cv-00183-EGB

Document 9

Filed 06/28/2007

Page 1 of 3

IN THE UNITED STATES COURT OF FEDERAL CLAIMS

) ) Plaintiff, ) ) v. ) ) THE UNITED STATES, ) ) Defendant. ) _________________________________________ )

J.H. PARKER CONSTRUCTION CO., INC.,

Case No. 07-183C (Chief Judge Damich)

JOINT MOTION FOR ENLARGEMENT OF TIME TO FILE JOINT PRELIMINARY STATUS REPORT COME NOW Plaintiff, J.H. Parker Construction Co., Inc. ("Parker"), and Defendant, United States, and hereby move this honorable Court for an extension of time of fourteen (14) days, to and including July 23, 2007, within which to file their Joint Preliminary Status Report ("JPSR"). In support of their motion, the parties represent that: 1. 2. No previous extension has been requested or obtained; Counsel initially conferred on June 11, 2007 regarding the JPSR and disagree as

to the contents and discovery schedule to be included; 3. Counsel conferred again on June 26, 2007 and are working toward a

comprehensive discovery schedule to be agreed upon by both parties. Due to the size and scope of the project at issue, the parties are discussing the extent of discovery and expert participation required in this case; 4. Due to scheduling conflicts, counsel will be unavailable to resolve the

disagreement between the parties before July 9, 2007;

Case 1:07-cv-00183-EGB

Document 9

Filed 06/28/2007

Page 2 of 3

WHEREFORE, the parties respectfully request that this honorable Court grant an extension of time of 14 days, to and including July 23, 2007 within which to file their JPSR. Counsel for Defendant has authorized counsel for Parker to file this joint motion on his behalf.

Dated: June 28, 2007. Respectfully submitted,

________s/_______ Carter B. Reid, Esquire Watt, Tieder, Hoffar & Fitzgerald, L.L.P. 8405 Greensboro Drive, Suite 100 McLean, Virginia 22102 Tel: 703- 749-1000 Fax: 703-893-8029 [email protected] Counsel for Plaintiff

PETER D. KEISLER Assistant Attorney General JEANNE E. DAVIDSON Director _____s/______ Bryant G. Snee BRYANT G. SNEE Assistant Director _____s/______ James W. Poirier JAMES W. POIRIER Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor, 1100 L St, N.W Washington, D.C. 20530 Tel: 202-307-6289 Fax: 202-514-7969 [email protected] Counsel for Defendant

2

Case 1:07-cv-00183-EGB

Document 9

Filed 06/28/2007

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the forgoing document, Joint Motion For Enlargement Of Time To File Joint Preliminary Status Report, has been served upon all persons noted below by way of first-class mail, postage prepaid, or facsimile on the 28th day of June, 2007. Additionally, I certify that this case being designated as an electronic case in the court's CM/ECF system, notice of electronic filing constitutes a certificate of service as to all parties to whom electronic notice is sent.

James W. Poirier Trial Attorney U.S Department of Justice Commercial Litigation Branch Classification Unit/8th Floor 1100 L Street, N.W. Washington, D.C. 20530 Tel: 202-616-0856 Fax: 202-514-7969 Counsel for Defendant

_______s/________ Carter B. Reid Watt, Tieder, Hoffar & Fitzgerald, L.L.P. 8405 Greensboro Drive, Suite 100 McLean, Virginia 22102 Tel: (703) 749-1000 Fax: (703) 893-8029 E-mail: [email protected]

3