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

Case 1:06-cv-00418-NBF

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Filed 12/22/2006

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS HOH RIVER TIMBER COMPANY, Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) ) )

No. 06-418C (Judge Firestone)

DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME TO FILE JOINT PRELIMINARY STATUS REPORT Pursuant to United States Court of Federal Claims Rule 6.1, defendant, the United States, respectfully requests an enlargement of time of 14 days, from December 29, 2006, through and including January 12, 2007, for the parties to file their Joint Preliminary Status Report ("JPSR") in this matter. Plaintiff's counsel has indicated that he does not oppose this motion. This is our first request for an enlargement of time for

this purpose. Prior to the filing of the JPSR, undersigned counsel of record for the Government must obtain agency counsel's input and thereafter send a final draft to agency counsel for review and comment. However, agency counsel is out of the office from Further,

December 18, 2006 through December 22, 2006.

undersigned counsel will be out of the office from December 26, 2006 through at least December 29, 2006. In addition,

undersigned counsel anticipates being out of the office for depositions in Hooker v. United States, Consol. Nos. 03-1501C,

Case 1:06-cv-00418-NBF

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04-1126C, from January 8, 2007 through approximately January 10, 2007. Accordingly, an enlargement of time is required to

complete the JPSR and submit it for filing. CONCLUSION For the foregoing reasons, defendant respectfully requests that this Court grant this motion for an enlargement of time, through and including January 12, 2007, for the parties to submit the JPSR in this action. Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director

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Case 1:06-cv-00418-NBF

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s/Kathryn A. Bleecker by SJG KATHRYN A. BLEECKER Assistant Director s/Richard P. Schroeder RICHARD P. SCHROEDER Trial Attorney Commercial Litigation Branch Civil Division U.S. Department of Justice Attn: Classification Unit Eighth Floor 1100 L Street, N.W. Washington, D.C. 20530 Tele: (202) 305-7562 Attorneys for Defendant December 22, 2006

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Case 1:06-cv-00418-NBF

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CERTIFICATE OF FILING I hereby certify under penalty of perjury that on this 22nd day of December 2006, a copy of the foregoing "DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME TO FILE JOINT PRELIMINARY 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/Richard P. Schroeder