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

Case 1:06-cv-00306-MCW

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS TERESA KIM LANGE, Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 06-306C (Judge Williams)

DEFENDANT'S MOTION FOR AN ENLARGEMENT OF TIME, UPON BEHALF OF BOTH PARTIES Defendant, upon behalf of both parties, respectfully requests an enlargement of time of 14 calendar days, to and including January 18, 2007, within which to file the joint preliminary status report in this case. The parties' joint

preliminary status report currently is due to be filed on January 4, 2007. This is defendant's first request for an enlargement of Counsel for defendant has contacted

time for this purpose.

counsel for plaintiff regarding this motion, and he has stated that plaintiff concurs in this motion. The additional time is necessary because the parties have not yet completed their preparation of the joint preliminary status report. Although she has begun preparation of the joint

preliminary status report, undersigned counsel for defendant has not yet completed it. Specifically, in the past few weeks,

counsel for defendant has been responsible for the following: preparation for and participation in oral argument in Applied Companies v. Secretary of Defense, No. 2006-1360 (Fed. Cir.); preparation and filing of respondent's brief in

Case 1:06-cv-00306-MCW

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Flores v. Secretary of Veterans Affairs, No. 2006-7198 (Fed. Cir.); preparation and filing of defendant's reply to plaintiff's response to defendant's motion to dismiss in Lowe v. United States, No. 06-121C (Fed. Cl.); and reviewing documents in GTI, Inc. v. United States, No. 05-463 (Fed. Cl.). Additionally,

counsel for defendant was out of the office on annual leave from December 21, 2006 until January 3, 2007. Counsel for defendant expects to forward a draft of the joint preliminary status report to counsel for plaintiff within the next few days. The parties will thereafter confer, finalize, Counsel expect that an

and file the report with the Court.

enlargement of time of 14 calendar days will be sufficient for this purpose. For the foregoing reasons, we respectfully request that our motion for an enlargement of time, upon behalf of both parties, be granted.

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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/ Lauren S. Moore LAUREN S. MOORE Attorney Commercial Litigation Branch Civil Division Department of Justice 1100 L Street, N.W. Attn: Classification Unit 8th Floor Washington, D.C. 20530 Tele: (202) 307-6288 Fax: (202) 514-8640 Attorneys for Defendant JANUARY 4, 2007

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CERTIFICATE OF ELECTRONIC FILING I hereby certify that on the 4th day of January, 2007, a copy of the foregoing "DEFENDANT'S MOTION FOR AN ENLARGEMENT OF TIME, UPON BEHALF OF BOTH PARTIES" 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, and that the parties may access this filing through the Court's system. /s/ Lauren S. Moore