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

Case 1:07-cv-00160-EGB

Document 9

Filed 09/13/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS J.O.A. CONSTRUCTION CO., INC., Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 07-160C (Judge Bruggink)

DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME WITHIN WHICH TO FILE THE JOINT PRELIMINARY STATUS REPORT Defendant respectfully requests an enlargement of time of 10 days, to and including September 27, 2007, within which to file the Joint Preliminary Status Report ("JPSR"). The Court previously granted plaintiff's request for a 30-day enlargement of time, which the Government did not oppose, to file the JPSR until September 17, 2007. This is defendant's first request for an enlargement of time for this purpose. Plaintiff's counsel does not oppose this request. This motion is necessary to enable counsel to prepare adequately the Government's response to the draft JPSR that it received from plaintiff on September 12, 2007. Defendant's counsel will be traveling to Portland, Oregon, during the week of September 17, 2007, to conduct pretrial activities in the case of The Dalles Irrigation District v. United States, No. 051042C (Fed. Cl.), and needs additional time to prepare the Government's response.

Case 1:07-cv-00160-EGB

Document 9

Filed 09/13/2007

Page 2 of 3

For these reasons, defendant respectfully requests that the Court grant its motion for a 10day enlargement of time within which to file the JPSR. Respectfully submitted, PETER D. KEISLER Assistant Attorney General JEANNE E. DAVIDSON Director s/ Martin F. Hockey, Jr. MARTIN F. HOCKEY, JR. 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 13, 2007 Attorneys for Defendant

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Case 1:07-cv-00160-EGB

Document 9

Filed 09/13/2007

Page 3 of 3

CERTIFICATE OF FILING I hereby certify that on this 13th day of September, 2007, a copy of the foregoing "DEFENDANT'S UNOPPOSED 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