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

Case 1:06-cv-00381-TCW

Document 8

Filed 10/16/2006

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS TODD CONSTRUCTION CO., INC., Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 06-381C (Judge Wheeler)

DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Defendant respectfully requests an enlargement of time of 14 days, to and including October 30, 2006, within which to file our joint preliminary status report ("JPSR"). The JPSR is now due to be filed on October 16, 2006. This is defendant's first request for an enlargement of time for this purpose. Defendant has communicated with plaintiff's counsel, who does not oppose this motion. Defendant's counsel has been engaged in preparing the Government's reply briefs in a bid protest case, Textron v. United States, Fed. Cl. 06-517, due on October 16, 2006, and also preparing for oral argument, scheduled to occur on Wednesday, October 18, 2006, in the same case. Plaintiff's counsel is currently out of the office on business travel, and was engaged in hearings last week. The parties have therefore been unable to complete a draft of the JPSR. Once the parties have completed such a draft, defendant will require time to receive comments on the draft from the agency, and to obtain necessary supervisory review. For these reasons, the parties respectfully request that the Court grant their motion for a 14-day enlargement of time within which to file their JPSR.

Case 1:06-cv-00381-TCW

Document 8

Filed 10/16/2006

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Respectfully submitted,

PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director s/ Steven J. Gillingham STEVEN J. GILLINGHAM Assistant Director s/ Sean B. McNamara SEAN B. McNAMARA Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L St., NW Washington, D.C. 20530 Tele: (202) 305-7573 Fax: (202) 514-8624 October 16, 2006 Attorneys for Defendant

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Case 1:06-cv-00381-TCW

Document 8

Filed 10/16/2006

Page 3 of 3

CERTIFICATE OF FILING I hereby certify that on this 16th day of October, 2006, a copy of the foregoing "DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME" 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. The parties may access this filing through the Court's system.

s/ Sean B. McNamara