Free Motion to Amend Schedule - District Court of Federal Claims - federal

Case 1:06-cv-00310-TCW

Document 5

Filed 07/28/2006

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS TEKNOWLEDGE CORPORATION, ) ) Plaintiff, ) ) v. ) ) THE UNITED STATES, ) ) Defendant. )

No. 06-310C (Judge Thomas C. Wheeler)

DEFENDANT'S REQUEST FOR ENLARGEMENT OF TIME ON BEHALF OF PARTIES TO FILE JPSR Defendant, the United States, respectfully requests on behalf of both parties an enlargement of time of 25 days, to and including September 8, 2006, to prepare and file the parties' Joint Preliminary Status Report (JPSR). The JPSR is currently due on August 14, 2006. This is the parties' first request for an extension of time for this purpose. Defendant's counsel has contacted plaintiff's counsel who represents that he will join us in this motion. The parties have discussed the issues pertaining to the preparation of the JPSR. However, they require additional time to discuss the various proposals under consideration with their clients and to reach agreement upon the JPSR language. Counsel for the Government will be out of the office from August 2 through 18, 2006, and counsel for the plaintiff will be out of the office from August 21 through 25, 2006. Therefore, the parties will not be able to complete their preparation of the JPSR until the first week in September 2006. For these reasons, we respectfully request that the Court grant our request for enlargement of time. Respectfully submitted, PETER D. KEISLER Assistant Attorney General

Case 1:06-cv-00310-TCW

Document 5

Filed 07/28/2006

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/s/ David M. Cohen DAVID M. COHEN Director

OF COUNSEL: STACY PROCTER Defense Contract Management Agency Carson, CA 90746

/s/ Sheryl L. Floyd SHERYL L. FLOYD Senior Trial Counsel Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L Street, N.W. Washington, D.C. 20530 Tele: (202) 307-0282 Attorneys for Defendant

JULY 28, 2006

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Case 1:06-cv-00310-TCW

Document 5

Filed 07/28/2006

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CERTIFICATE OF FILING I hereby certify that on this 28th day of JULY, 2006, a copy of "DEFENDANT'S REQUEST FOR ENLARGEMENT OF TIME ON BEHALF OF PARTIES TO FILE JPSR" 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/ Sheryl L. Floyd