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

Case 1:07-cv-00165-JFM

Document 16

Filed 08/08/2007

Page 1 of 3

IN THE UNITED STATES COURT OF FEDERAL CLAIMS

) ) ) Plaintiff, ) v. ) ) UNITED STATES, ) ) Defendant. ) __________________________________________)

HERNANDEZ, KROONE AND ASSOCIATES, INC.,

NO. 07-165C (Judge Merow)

DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME TO FILE THE JPSR

Defendant respectfully requests that this Court grant the parties an enlargement of time of 22 days, to and including August 31, 2007, within which to file their Joint Preliminary Status Report ("JPSR"). The parties' JPSR currently is due Thursday, August 9, 2007. This is defendant's first request for an enlargement of time for this purpose. Plaintiff has consented to the instant motion. Our motion for an enlargement of time is necessary because additional time is required to enable counsel for the parties to complete the Early Meeting of Counsel and the JPSR required by Appendix A of the Rules of this Court. We regret the late filing of this motion. Until very recently, however, we believed that we would be able to complete the JPSR by the current deadline. In addition, counsel for defendant will be out of the office and unavailable from August 11-26, 2007. For the foregoing reasons, defendant respectfully requests that the Court grant its motion for an enlargement of time of 22 days, to and including August 31, 2007, within which to file the parties' JPSR.

Case 1:07-cv-00165-JFM

Document 16

Filed 08/08/2007

Page 2 of 3

Respectfully submitted, PETER D. KEISLER Assistant Attorney General JEANNE E. DAVIDSON Director s/ Mark A. Melnick by s/ K. Bleecker MARK A. MELNICK Assistant Director s/ Matthew H. Solomson MATTHEW H. SOLOMSON Trial Attorney, Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit, 8th Floor 1100 L Street, N.W. Washington, D.C. 20530 Tel: (202) 305-3274 Fax: (202) 514-8624 August 8, 2007 Attorneys for Defendant

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Case 1:07-cv-00165-JFM

Document 16

Filed 08/08/2007

Page 3 of 3

CERTIFICATE OF SERVICE

I hereby certify that, on this 8th day of August 2007, I caused to be filed electronically the foregoing DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME with the United States Court of Federal Claims. I understand that notice of this filing will be sent to all parties by operation of the Court's electronic filing system. Parties may access this filing through the Court's system.

s/ Matthew H. Solomson MATTHEW H. SOLOMSON