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

Case 1:07-cv-00056-EJD

Document 13

Filed 07/13/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS

BASS MANAGEMENT, INC.,

) ) Plaintiff, ) ) v. ) ) THE UNITED STATES, ) ) ) Defendant . ) ____________________________________)

Case No. 07-056C (Chief Judge Damich)

JOINT MOTION FOR ENLARGEMENT OF TIME The parties respectfully request an extension of time of four days to and including July 20, 2007, to file a revised Joint Preliminary Status Report ("JPSR"). The JPSR is now due to be filed on July 16, 2007.1 This is the parties' first request for an extension of time for this purpose. The parties seek an enlargement in time because both parties need additional time to review, revise, and edit the JPSR before submitting it to this Court. The allegations at issue are multiple and varied. The plaintiff's seven count complaint encompasses 26 pages and 155 paragraphs. The plaintiff also filed on July 9, 2007, a motion for leave to amend its complaint to add another count to the complaint. Due to the multiple allegations at issue, additional time is also necessary for undersigned counsel to consult with their respective clients to complete preparation of the JPSR. Additional time will also permit Government counsel to obtain necessary supervisory review. For the foregoing reasons, we respectfully request that our motion be granted.

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The parties initially filed a JPSR in this matter on June 18, 2007. This Court ordered the parties on June 29, 2007 to file a revised JPSR on or before July 16, 2007.

Case 1:07-cv-00056-EJD

Document 13

Filed 07/13/2007

Page 2 of 3

Respectfully submitted, /s/ Frank W. Trapp Frank W. Trapp, MB #8261 Phelps Dunbar LLP 111 East Capitol Street · Suite 600 Jackson, Mississippi 39201-2122 P. O. Box 23066 Jackson, Mississippi 39225-3066 Telephone: (601) 352-2300 Facsimile: (601_360-9777 Attorneys for plaintiff

PETER D. KEISLER Assistant Attorney General JEANNE E. DAVIDSON Director /s Kathryn A. Bleecker KATHRYN A. BLEECKER Assistant Director s/ David M. Hibey DAVID M. HIBEY Trial Attorney Commercial Litigation Branch Civil Division Department of Justice 1100 L Street, N.W. Attn: Classification Unit 8th Floor Washington, D.C. 20530 Tel: (202) 307-0163 Fax: (202) 514-8624

July 13, 2007

Attorneys for Defendant

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Case 1:07-cv-00056-EJD

Document 13

Filed 07/13/2007

Page 3 of 3

CERTIFICATE OF FILING I hereby certify that on this 13th day of July, 2007, a copy of the foregoing "Joint Motion for 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. Parties may access this filing through the Court's system.

/s David M. Hibey

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