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

Case 1:06-cv-00360-LMB

Document 23

Filed 07/06/2006

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS ) ) ) Plaintiff, ) ) v. ) ) THE UNITED STATES, ) ) Defendant, ) ) and ) ) 4041 CENTRAL PLAZA, L.L.C., ) ) Intervenor. ) __________________________________________) 210 EARLL, L.L.C., __________________________________________

Case No. 06-360C (Judge Baskir)

INTERVENOR'S UNOPPOSED MOTION TO EXTEND TIME TO FILE ITS MOTION ON THE ADMINISTRATIVE RECORD Under Rule 6.1, Intervenor, 4041 Central Plaza, L.L.C. ("4041 Central") respectfully moves for an enlargement of time for an additional seven (7) days, to and including July 17, 2006, to file its motion for judgment on the administrative record. It is hereby represented that this motion is unopposed by counsel for the Plaintiff and Defendant. Intervenor's Motion for Judgment on the Administrative Record is presently due on July 10, 2006. Counsel for the Defendant, the United States, has filed a request for an enlargement of time due, in large part, on disruptions to the Department of Justice's computer network arising from recent severe weather in the Washington, D.C. area. Intervenor files this motion for an enlargement of time in order to align the time and

Case 1:06-cv-00360-LMB

Document 23

Filed 07/06/2006

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sequence for filing the Defendant's Motion and Intervenor's Motion and to coordinate and prepare a proper mutual defense with Defendant, the United States, in this matter. No enlargements of time have been previously requested by Intervenor in this case. For the foregoing reasons, Intervenor respectfully requests that the Court grant this unopposed motion for an enlargement of time.

Respectfully submitted,

/s/ Richard L. Moorhouse RICHARD L. MOORHOUSE GREENBERG TRAURIG, LLP 1750 Tysons Blvd. Suite 1200 McLean, VA 22101 Tel.: (703)749-1300 Fax: (703)749-1301

Case 1:06-cv-00360-LMB

Document 23

Filed 07/06/2006

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CERTIFICATE OF FILING I hereby certify that on this 6th day of July, 2006, a copy of the foregoing "Intervernor's Unopposed Motion to Extend Time to File Its Motion on the Administrative Record" was filed electronically. I understand that notice of this filing will be sent to all parties of operation of the Court's electronic filing system. Parties may access this filing through the Court's system.

/s/ Richard L. Moorhouse RICHARD L. MOORHOUSE GREENBERG TRAURIG, LLP 1750 Tysons Blvd. Suite 1200 McLean, VA 22101 Tel.: (703)749-1300 Fax: (703)749-1301