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

Case 1:07-cv-00174-CFL

Document 20

Filed 02/07/2008

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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)

JOINT MOTION FOR AN ENLARGEMENT OF TIME WITHIN WHICH TO FILE THE JOINT PRELIMINARY STATUS REPORT Plaintiff and defendant respectfully request an enlargement of time of 60 days, to and including April 22, 2008, within which to file the joint preliminary status report which is currently due on February 22. 2008. Defendant's counsel will be out of the office from February 11-18, 2008, while plaintiff's counsel will be out of the office from February 15-27, 2008. Upon their return, counsel for the parties will continue to work towards resolving the issues set forth in the complaint and desire additional time for this purpose. Respectfully submitted, JEFFREY S. BUCHHOLZ Acting Assistant Attorney General JEANNE E. DAVIDSON Director s/ Brian M. Simkin BRIAN M. SIMKIN Assistant Director

Case 1:07-cv-00174-CFL

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Filed 02/07/2008

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s/ Fred J. Livingstone FRED J. LIVINGSTONE Taft Stettinus & Hollister LLP 200 Public Sqaure, Suite 3500 Cleveland, OH 44114 Tel: (216) 241-2838 Fax: (216) 241-3707

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 Tel: (202) 307-3390 Fax: (202) 514-8624 Attorneys for Defendant

Attorney for Plaintiffs 7 February ___, 2008

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Case 1:07-cv-00174-CFL

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Filed 02/07/2008

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CERTIFICATE OF FILING 7 I hereby certify that on this ___th day of February, 2008, a copy of the foregoing "JOINT MOTION FOR AN ENLARGEMENT OF TIME WITHIN WHICH TO FILE THE JOINT PRELIMINARY STATUS REPORT" 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