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

Case 1:06-cv-00401-NBF

Document 28

Filed 06/27/2008

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS ) ) Plaintiff, ) ) v. ) ) UNITED STATES OF AMERICA, ) ) Defendant. ) __________________________________________) JILLINA MANION,

No. 06-401L Hon. Nancy B. Firestone

JOINT MOTION FOR ENLARGEMENT OF TIME TO FILE THE PARTIES' POSTDISCOVERY STATUS REPORT ______________________________________________________________________________ Pursuant to Rule 6.1 of the Rules of the Court of Federal Claims, the parties hereby respectfully move for an enlargement of time of fourteen (14) days, or to and including July 14, 2008, for the filing of their post-discovery status report. Discovery in this matter closed on June 23, 2008. By this Court's order of June 23, 2008 the parties were directed to file a post-discovery status report on June 30, 2008. (Docket No. 27). The parties respectfully request that the deadline for this filing be extended fourteen days, or to and including July 14, 2008. The parties require this additional time due to the recency of the close of discovery and some outstanding issues on which the parties are working toward an agreement. The parties are in agreement that this motion should be granted. WHEREFORE, the parties respectfully request that the Court grant them an enlargement of time of fourteen (14) days, or to and including July 14, 2008, for the filing of their postdiscovery status report.

Case 1:06-cv-00401-NBF

Document 28

Filed 06/27/2008

Page 2 of 2

Respectfully submitted by Defendant on behalf of the parties this 27th day of June, 2008,

RONALD J. TENPAS Acting Assistant Attorney General Environment and Natural Resources Division s/ Mark T. Romley Mark T. Romley Trial Attorney Natural Resources Section Environment & Natural Resources Division United States Department of Justice P. O. Box 663 Washington, D.C. 20044-0663 Telephone: (202) 305-0458 Fax: (202) 305-0506