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

Case 1:07-cv-00174-CFL

Document 13

Filed 09/28/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS PENNSAUKEN SENIOR TOWERS URBAN RENEWAL ASSOCIATES LLC & HOUSING AUTHORITY OF THE TOWNSHIP OF PENNSAUKEN, Plaintiffs, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) ) ) )

No. 07-174C (Judge Lettow)

DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Defendant respectfully requests an enlargement of time of 33 days, to and including November 13, 2007, within which to file the Joint Preliminary Status Report ("JPSR") that is currently due on October 11, 2007. This is defendant's first request for an enlargement of time for this purpose. Defendant has contacted plaintiff's counsel who has indicated that plaintiff does not oppose this request. Both sides are actively engaged in considering settlement of plaintiff's claims and would like more time to continue settlement discussions. For these reasons, defendant respectfully requests that the Court grant its unopposed motion for a 33-day enlargement of time within which to file the JPSR. Respectfully submitted, PETER D. KEISLER Assistant Attorney General JEANNE E. DAVIDSON Director

Case 1:07-cv-00174-CFL

Document 13

Filed 09/28/2007

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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 September 28, 2007 Attorneys for Defendant

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Case 1:07-cv-00174-CFL

Document 13

Filed 09/28/2007

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CERTIFICATE OF FILING I hereby certify that on this 28 th day of September, 2007, a copy of the foregoing "DEFENDANT'S 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. The parties may access this filing through the Court's system.

s/ Armando Rodriguez-Feo