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

Case 1:06-cv-00377-GWM

Document 15

Filed 03/19/2007

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS

ROME RESEARCH CORPORATION, Plaintiff, Case No. 1:06-cv-377 v. UNITED STATES, Defendant Judge George W. Miller

CONSENT MOTION TO EXTEND TIME FOR FILING JOINT PRELIMINARY STATUS REPORT

Plaintiff Rome Research Corporation, with the consent of the Defendant, United States, respectfully requests a brief extension of the deadline for submitting the Parties' Joint Preliminary Status Report. Counsel for the Parties have conferred and have reached preliminary agreement on the required elements of the report, including a proposed schedule for discovery; however, internal client and Department of Justice approval needs to be finalized before a joint, agreed report may be submitted. The Parties anticipate that this approval will be obtained and that their report will be filed on or before Friday, March 23, 2007.

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Case 1:06-cv-00377-GWM

Document 15

Filed 03/19/2007

Page 2 of 2

CONCLUSION For the foregoing reasons, Plaintiff, with the consent of the Defendant, respectfully requests that the Court extend the time for filing the Joint Prelinary Status Report in this matter until March 23, 2007.

Respectfully submitted,

s/ DANIEL B. ABRAHAMS Epstein Becker & Green, P.C. 1227 25th Street, N.W., Suite 600 Washington, D.C. 20037 Tel: (202) 861-1854 Dated: March 19, 2007

CERTIFICATE OF SERVICE I hereby certify under penalty of perjury that on this 19th day of March, 2007, a copy of the foregoing "Consent Motion to Extend Time for Filing 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/ Daniel B. Abrahams

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