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

Case 1:06-cv-00448-GWM

Document 34

Filed 10/22/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS MICHAEL KAWA, Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 06-448C (Judge George W. Miller)

DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Pursuant to Rules 6(b) and 6.1 of the Rules of the United States Court of Federal Claims ("RCFC"), defendant, the United States, respectfully requests that the Court grant an enlargement of time of seven days, to and including November 2, 2007, within which to prepare and file the joint preliminary status report ("JPSR"). The JPSR is currently due on October 26, 2007. This is our first request for an enlargement of time for this purpose. Defendant's counsel contacted plaintiff's counsel, and was informed that plaintiff does not object to this motion for enlargement of time. The enlargement of time requested is necessary because defendant's counsel attempted to contact plaintiff's counsel on October 10, 18, and 22, 2007 regarding the JPSR, but did not receive a response from plaintiff's counsel until October 22, 2007. Thus, the parties require additional time to discuss and prepare the JPSR. Accordingly, we respectfully request that the Court grant defendant's unopposed motion for an enlargement of time of seven days, to and including November 2, 2007, in which to file the JPSR.

Case 1:06-cv-00448-GWM

Document 34

Filed 10/22/2007

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Respectfully Submitted, PETER D. KEISLER Assistant Attorney General JEANNE E. DAVIDSON Director /s/ FRANKLIN E. WHITE, JR. FRANKLIN E. WHITE, JR. Assistant Director /s/ MEREDYTH D. COHEN MEREDYTH D. COHEN Trial Attorney Commercial Litigation Branch Civil Division Department of Justice 1100 L Street NW Attn: Classification Unit 8th Floor Tel: (202) 353-7978 Fax: (202) 514-8624 Washington, DC 20530 October 22, 2007 Attorneys for Defendant

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Case 1:06-cv-00448-GWM

Document 34

Filed 10/22/2007

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that on the 22nd day of October, 2007 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. Parties may access this filing through the Court's system.

/s/MEREDYTH D. COHEN