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

Case 1:06-cv-00418-NBF

Document 27

Filed 04/25/2007

Page 1 of 3

IN THE UNITED STATES COURT OF FEDERAL CLAIMS

Hoh River Timber Company, a Washington corporation, Plaintiff, No. 06-418C v. (Judge Firestone) The United States, Defendant. PLAINTIFF'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME TO FILE JOINT STATUS REPORT Pursuant to United States Court of Federal Claims Rule 6.1, plaintiff Hoh River Timber Company respectfully requests an enlargement of time of 7 days, from April 26, 2007, through and including May 3, 2007, for the parties to file their Joint Status Report ("JSR"). Defendant's counsel has indicated that the United States does not oppose this motion. We have not previously been granted an enlargement of time for this purpose. Counsel for the parties have exchanged JSR drafts with each other and are currently discussing the order in which proposed areas will be visited during the May 10, 2007 site visit. The United States is currently reviewing plaintiff's proposed revisions to the draft JSR.

Portlnd3-1582816.1 0015361-00002

Case 1:06-cv-00418-NBF

Document 27

Filed 04/25/2007

Page 2 of 3

In addition, plaintiff's counsel is out of the office April 26, 2007 through April 29, 2007 for an out of state firm meeting. Although undersigned counsel previously believed that there would be sufficient time to complete the JSR despite the need for this absence, a brief additional enlargement is required. CONCLUSION For the foregoing reasons, plaintiff respectfully requests that the Court grant this motion for an enlargement of time, through and including May 3, 2007, for the parties to submit the JSR in this action.

Respectfully submitted,

s/Louis A. Ferreira LOUIS A. FERREIRA Stoel Rives LLP 900 SW Fifth Avenue, Suite 2600 Portland, OR 97204-1268 (503) 224-3380 Attorneys for Plaintiff Of Counsel: Charles F. Adams Stoel Rives LLP 900 SW Fifth Avenue, Suite 2600 Portland, OR 97204 Telephone: (503) 224-3380 Facsimile: (503) 220-2480

Portlnd3-1582816.1 0015361-00002

Case 1:06-cv-00418-NBF

Document 27

Filed 04/25/2007

Page 3 of 3

CERTIFICATE OF FILING I hereby certify under penalty of perjury that on this 25th day of April, 2007, a copy of the foregoing "PLAINTIFF'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME TO FILE JOINT STATUS REPORT" 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/Louis A. Ferreira Louis A. Ferreira

Portlnd3-1582816.1 0015361-00002