Free Motion to Amend Schedule - District Court of Federal Claims - federal

Case 1:07-cv-00174-CFL

Document 29

Filed 07/07/2008

Page 1 of 3

IN THE UNITED STATES COURT OF FEDERAL CLAIMS PENNSAUKEN SENIOR TOWERS URBAN RENEWAL ASSOCIATES, LLC, ET AL., Plaintiffs, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) ) )

No. 07-174C No. 07-646C (Judge Lettow)

DEFENDANT'S UNOPPOSED MOTION TO RESCHEDULE HEARING UPON DEFENDANT'S MOTION TO DISMISS, IN PART Defendant respectfully requests that this Court reschedule the hearing upon defendant's motion, which the Court set for July 22, 2008, at 10:00 a.m. Defendant conferred with plaintiff's counsel who does not oppose our request provided that the new hearing date occurs after August 10, 2008. We request that the hearing be rescheduled for the week of August 18, 2008, or at a later time convenient to the Court. The reason for this request is that defendant's counsel of record will be out of the office from July 19 through July 26, 2008 in connection with the case of Great Lakes v. United States, No. 07-218C (Fed. Cl.) (a hearing is set in West Palm Beach, Florida for July 21, 2008) and four days vacation. Plaintiff's counsel, however, will be out the office until August 10, 2008, and defendant's counsel of record will be away from August 9 through 16, 2008 in connection with the taking and defending of depositions in the case of Aliamanu Conservation Partners, Inc., v. United States, No. 07-134C (Fed. Cl.).

Case 1:07-cv-00174-CFL

Document 29

Filed 07/07/2008

Page 2 of 3

Accordingly, the Government respectfully requests that the Court reschedule the hearing upon our motion for the week of August 18, 2008, or at a later time convenient to the Court. Respectfully submitted, GREGORY G. KATSAS Assistant Attorney General JEANNE E. DAVIDSON Director s/Brian M. Simkin BRIAN M. SIMKIN Assistant Director s/Armando Rodriguez-Feo ARMANDO A. RODRIGUEZ-FEO Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit, 8th Floor 1100 L St., NW Washington, D.C. 20530 Tele: (202) 307-3390 Fax: (202) 514-8624 July 7, 2008 Attorneys for Defendant

-2-

Case 1:07-cv-00174-CFL

Document 29

Filed 07/07/2008

Page 3 of 3

CERTIFICATE OF FILING I hereby certify that on this 7th day of July, 2008, a copy of the foregoing "DEFENDANT'S UNOPPOSED MOTION TO RESCHEDULE HEARING UPON DEFENDANT'S MOTION TO DISMISS, IN PART" 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. The parties may access this filing through the Court's system.

s/Armando Rodriguez-Feo