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

Case 1:06-cv-00432-LSM

Document 46

Filed 05/21/2008

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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 ENLARGEMENT OF TIME Pursuant to Rules 6 and 6.1 of the Rules of the United States Court of Federal Claims, defendant, the United States, respectfully requests the Court to enlarge by two days, to and including May 23, 2008, the due date for the revised stipulation concerning quantum, which the Court requested during the telephonic status conference on May 14, 2008. This is our first such request concerning this deadline. Adam P. Feinberg, counsel for plaintiff, Continental Airlines, Inc., states that plaintiff does not oppose this motion. The parties have exchanged several drafts of the revised stipulation but have not yet agreed upon its contents. Mr. Feinberg will be unavailable for much of today, May 21. Moreover, undersigned counsel for defendant will need to obtain supervisory review before the document can be filed. We are optimistic, however, that a two-day enlargement, to and including May 23, will permit us to complete and file the revised quantum stipulation. Respectfully submitted, GREGORY G. KATSAS Acting Assistant Attorney General s/Jeanne E. Davidson JEANNE E. DAVIDSON Director

Case 1:06-cv-00432-LSM

Document 46

Filed 05/21/2008

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OF COUNSEL: ANDREW S. KOSEGI Attorney U.S. Customs and Border Protection Indianapolis, IN CYNTHIA A. KOCH Senior Counsel United States Department of Agriculture Washington, D.C. May 21, 2008 s/Kyle Chadwick KYLE CHADWICK Senior Trial Counsel Commercial Litigation Branch Civil Division Department of Justice Attn: Classification, 8th Floor 1100 L Street, N.W. Washington, D.C. 20530 Tele: (202) 305-7562 Fax: (202) 305-7644 Attorneys for Defendant

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Case 1:06-cv-00432-LSM

Document 46

Filed 05/21/2008

Page 3 of 3

CERTIFICATE OF FILING I certify that on May 21, 2008, the attached was filed electronically. I understand that service is complete upon filing and that parties and others may access the filing through the Court's system. s/Kyle Chadwick

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