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

Case 1:07-cv-00160-EGB

Document 8

Filed 08/16/2007

Page 1 of 2

IN THE UNITED STATES FEDERAL COURT OF CLAIMS J.O.A. CONSTRUCTION CO., INC., A Michigan corporation Plaintiff V THE UNITED STATES. Defendant Case Number: 07-160C Senior Judge Brugginlk

PLAINTIFF'S MOTION FOR AN ENLARGEMENT OF TIME Plaintiff respectfully requests as enlargement of time of 31 days, to and including September 17, 2007, within to file its Joint Preliminary Status Report. The Joint Preliminary Status Report is presently due August 17, 2007. This is Plaintiff's first request for an enlargement of time for this purpose. Plaintiff's counsel has contacted Defendant's counsel, who has no objection to the granting of an enlargement of time as requested. This motion is necessary for the Plaintiff's counsel to complete the preparation of its status report and to give Defendant's counsel sufficient time to add its required statements also. Plaintiff's counsel has been out of the country for several weeks during the time allowed for the production of the status report and counsel has underestimated the time required to complete the preparation of such status report. For these reasons Plaintiff respectfully requests that the Court grant its motion for a 31 day enlargement of time to file its Joint Preliminary Status Report. /s/ John K. Grylls JOHN K. GRYLLS Attorney for Plaintiff 18430 Mack Avenue Grosse Pointe Farms, MI 48236 Tel: (313) 885-0123 Fax: (313) 886-7699

Case 1:07-cv-00160-EGB

Document 8

Filed 08/16/2007

Page 2 of 2

PETER D. KEISLER Assistant Attorney General JEANNE E DAVIDSON Director MARTIN F. HOCKEY, JR. Assistant Director ARMANDO A. RODRIGUEZ-FEO Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L. Street, NW Washington DC 20530 Tel: (202) 307-3390 Fax: (202) 514-8624 Date: August 16, 2007 Attorneys for Defendant