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


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Date: April 17, 2008
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Case 1:06-cv-00167-TCW

Document 44

Filed 04/17/2008

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS ) ) ) ) ) ) ) ) ) ) )

OTAY MESA PROPERTY L.P., et al., Plaintiffs, v. UNITED STATES, Defendant.

No. 06-167L Hon. Lawrence M. Baskir

UNOPPOSED MOTION FOR LEAVE TO FILE UNOPPOSED MOTION FOR ENLARGEMENT OF TIME TO FILE JOINT STATUS REPORT AND UNOPPOSED MOTION FOR ENLARGEMENT OF TIME TO FILE JOINT STATUS REPORT Pursuant to RCFC 6(b), Plaintiffs, Otay Mesa Property, L.P., et al., hereby submit this Unopposed Motion for Leave to File Unopposed Motion for Enlargement of Time to File Joint Status Report and Unopposed Motion for Enlargement of Time to File Joint Status Report. For the following reasons, Plaintiffs respectfully request the Court to enlarge the deadline for the Joint Status Report by seven (7) days to, and including, April 24, 2008. Under the Court's March 17, 2008 Order, the parties are scheduled to file a Joint Status Report on April 17, 2008, indicating how they wish to proceed in this matter. However, lead counsel for the Government advised counsel for Plaintiffs on April 17, 2008, that she was out of the country from March 27 to April 13, 2008. After returning home, counsel for the Government became severely ill and has been unable to work from April 14, 2008 through today. As a result, the parties have been unable to meet and confer on the Joint Status Report. Indeed, Plaintiffs are filing this Motion as a courtesy to the Government because of counsel for the Government's continued illness. Accordingly, for the above reasons, it was impossible to file this motion before today.

Case 1:06-cv-00167-TCW

Document 44

Filed 04/17/2008

Page 2 of 2

Accordingly, Plaintiffs respectfully request an enlargement of time of seven (7) days to, and including, April 24, 2008, to file the Joint Status Report with the Court.

Dated: April 17, 2008

Respectfully submitted,

s/ Roger J. Marzulla Roger J. Marzulla Nancie G. Marzulla MARZULLA & MARZULLA 1350 Connecticut Ave., N.W. Suite 410 Washington, DC 20036 (202) 822-6760 (telephone) (202) 822-6774 (facsimile) Counsel for Plaintiffs