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

Case 1:06-cv-00360-LMB

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Filed 05/22/2006

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS

) ) Plaintiff, ) ) v. ) ) UNITED STATES, ) ) Defendant, ) and ) ) 4041 CENTRAL PLAZA, L.L.C. ) ) Intervenor-Defendant. )

210 EARLL, L.L.C.,

No. 06-360C (Judge Baskir)

DEFENDANT'S UNOPPOSED MOTION TO EXTEND TIME TO FILE ADMINISTRATIVE RECORD Pursuant to Rule 6(b) of the Rules of the United States Court of Federal Claims ("RCFC"), defendant respectfully requests an enlargement of time of two calendar days, to and including May 24, 2006, in which to file the administrative record. The administrative record is presently due May 22, 2006. This is defendant's first request for an enlargement of this deadline. Counsel for the United States has contacted counsel for the plaintiff and counsel for the intervenor, and they have agreed to this extension.

Case 1:06-cv-00360-LMB

Document 10

Filed 05/22/2006

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The additional time is required for Government counsel to complete indexing and scanning in the documents in the record. We first received some of the documents in this case on Wednesday, May 17, 2006, and have been receiving supplementary productions through Sunday, May 21, 2006. However, it has taken longer than anticipated to organize these records and scan them into the computer for electronic filing. For the foregoing reasons, defendant respectfully requests that the Court grant this motion for an enlargement of time. Respectfully submitted,

PETER D. KEISLER Assistant Attorney General

DAVID M. COHEN Director

/s/ Franklin E. White, Jr. FRANKLIN E. WHITE, JR. Assistant Director

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Case 1:06-cv-00360-LMB

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/s/ Steven M. Mager STEVEN M. MAGER Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L Street, NW Washington, D.C. 20530 Tele: (202) 616-2377 [email protected] May 22, 2006 Attorneys for Defendant

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Case 1:06-cv-00360-LMB

Document 10

Filed 05/22/2006

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CERTIFICATE OF FILING I hereby certify that on this 22nd day of May, 2006, a copy of the foregoing "UNOPPOSED MOTION TO EXTEND TIME TO FILE ADMINISTRATIVE RECORD" 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/ Steven M. Mager Steven M. Mager Trial Attorney Commercial Litigation Branch Civil Division Department of Justice