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

Case 1:06-cv-00451-EGB

Document 7

Filed 10/23/2006

Page 1 of 3

IN THE UNITED STATES COURT OF FEDERAL CLAIMS JOHN MEREDITH, Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) )

No. 06-451 (Judge Bruggink)

DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Pursuant to Rule 6(b) of the Rules of the United States Court of Federal Claims ("RCFC"), defendant requests an enlargement of time of 30 days, to and including November 27, 2006, within which to file the parties' Joint Preliminary Status Report ("JPSR"). The JPSR presently is due on October 27, 2006.

This is our first request for an enlargement of time for this purpose. Plaintiff's counsel has been contacted and does not

oppose this request for an enlargement of time. Agency counsel has provided defendant's counsel with a litigation report as required pursuant to 28 U.S.C. § 520. Additional work is necessary, however, in order for defendant's counsel to be in a position to fully address the issues in this case as required by the JPSR. Therefore, we anticipate that an

additional 30 days will be required to conduct the additional investigation, obtain agency comment and internal review and approval of the government's JPSR responses and to coordinate final preparation and filing of the JPSR with plaintiff's counsel. For the foregoing reasons, defendant requests that the Court

Case 1:06-cv-00451-EGB

Document 7

Filed 10/23/2006

Page 2 of 3

grant this motion for an enlargement of time.

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 October 23, 2006

Case 1:06-cv-00451-EGB

Document 7

Filed 10/23/2006

Page 3 of 3

CERTIFICATE OF FILING

I hereby certify that on this 23rd day of October, 2006, a copy of the foregoing "DEFENDANT'S 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. filing through the Court's system. Parties may access this

s/ Robert E. Chandler