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

Case 1:06-cv-00432-LSM

Document 52

Filed 07/30/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS CONTINENTAL AIRLINES, INC., Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 06-432C (Senior Judge Margolis)

DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Defendant, the United States, respectfully requests that the Court grant an enlargement of time of 14 days, to and including August 14, 2008, within which the parties may file the proposed order requested by the Court at the status conference on July 16, 2008. The proposed order is currently due on July 31, 2008. Counsel for the

This is the first motion for this purpose.

plaintiff, Continental Airlines, Inc. ("Continental"), has authorized us to state that Continental does not oppose this motion. Counsel for the United States is newly assigned to this case,1 and needs some time to become familiar with the facts and law before the proposed order is filed. During the past week,

counsel has been required to devote nearly all of his time to Fireman's Fund v. United States, No. 04-1692C (Fed. Cl.) and HM2 Corporation v. United States, No. 05-551C (Fed. Cl.). Discovery

has been extremely active in both cases, and motions are likely

1

His appearance was filed on July 23, 2008.

Case 1:06-cv-00432-LSM

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Filed 07/30/2008

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to be filed in both cases soon. The full enlargement of time requested is needed. Both the

Fireman's Fund case and the HM2 case are likely to be extremely active in coming weeks. In addition, counsel has several other

cases, including United States v. Intermax Trading Company, No. 08-00117 (CIT), that will require his attention in early August. In addition, time will be needed for review by agency

counsel and by supervisors at the Department of Justice. For these reasons, we respectfully request that our unopposed motion be granted. Respectfully submitted, GREGORY G. KATSAS Acting Assistant Attorney General S/ Jeanne E. Davidson JEANNE E. DAVIDSON Director S/ James W. Poirier JAMES W. POIRIER Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor, 1100 L St, N.W. Washington, D.C. 20530 Tele: 202-616-0856 Fax: 202-514-7969 July 30, 2008 Attorneys for Defendant

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Case 1:06-cv-00432-LSM

Document 52

Filed 07/30/2008

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CERTIFICATE OF FILING I hereby certify that on July 30, 2008, 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. the Court's system. S/ James W. Poirier Parties may access this filing through