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

Case 1:06-cv-00451-EGB

Document 9

Filed 11/28/2006

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS

JOHN MEREDITH,

Plaintiff, v. THE UNITED STATES, Defendant.

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No. 06-451 (Judge Bruggink)

DEFENDANT'S MOTION FOR LEAVE TO FILE AN OUT OF TIME SECOND UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Defendant respectfully requests that the Court grant its motion for leave to file an out of time motion for an enlargement of time of 1 day, to and including November 28, 2006, within which to file the parties' Joint Preliminary Status Report ("JPSR"). The JPSR was due to be filed on November 27, 2006. This is defendant's second 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. The parties agreed upon a JPSR to be filed with the Court on November 27, 2006. As the result of a miscommunication between defendant's counsel and plaintiff's counsel, however, the document was not signed by plaintiff's counsel on that date, and therefore could not be filed with the Court. The JPSR has been signed by both parties, and is being submitted simultaneously with this motion for an enlargement of time. For the foregoing reasons, we respectfully request that our motion be granted.

Case 1:06-cv-00451-EGB

Document 9

Filed 11/28/2006

Page 2 of 3

Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director s/ Todd M. Hughes TODD M. HUGHES Assistant Director s/ Robert E. Chandler Robert E. Chandler Trial Attorney Commercial Litigation Branch Civil Division Department of Justice 1100 L St., N.W. Attn: Classification Unit 8th Floor Washington, D.C. 20530 Tel: (202) 307-1011 Attorneys for Defendant November 28, 2006

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Case 1:06-cv-00451-EGB

Document 9

Filed 11/28/2006

Page 3 of 3

CERTIFICATE OF FILING I hereby certify that on this 28nd day of November, 2006, a copy of the foregoing "DEFENDANT'S MOTION FOR LEAVE TO FILE AN OUT OF TIME SECOND 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/ Robert E. Chandler