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

Case 1:06-cv-00155-MMS

Document 39

Filed 08/12/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS S&M MANAGEMENT INCORPORATED, Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 06-155C (Judge Sweeney)

DEFENDANT'S SECOND UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Defendant respectfully requests an enlargement of time of 30 days, to and including September 12, 2008, within which to file the joint status report requested by the Court in its June 16, 2008 opinion and order and in its July 14, 2008 order. The joint status report is currently due by August 13, 2008. This is defendant's second request for an enlargement of time for this purpose. Defendant has contacted plaintiff's counsel, who has indicated that plaintiff does not oppose this request. The parties continue to be engaged in settlement discussions. The parties have conferred concerning settlement but have yet to reach an agreement, although progress has been made. An enlargement of 30 days should allow the parties sufficient time to explore the possibility of settling and to dismiss this matter if an agreement is reached. For these reasons, defendant respectfully requests that the Court grant its unopposed motion for a 30-day enlargement of time within which to file the joint status report. Respectfully submitted, GREGORY G. KATSAS Assistant Attorney General JEANNE E. DAVIDSON Director

Case 1:06-cv-00155-MMS

Document 39

Filed 08/12/2008

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s/ Franklin E. White, Jr. FRANKLIN E. WHITE, JR. Assistant Director s/ Sean B. McNamara SEAN B. McNAMARA Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit, 8th Floor 1100 L St., NW Washington, D.C. 20530 Tele: (202) 305-7573 Fax: (202) 514-8624 August 12, 2008 Attorneys for Defendant

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Case 1:06-cv-00155-MMS

Document 39

Filed 08/12/2008

Page 3 of 3

CERTIFICATE OF FILING I hereby certify that on this 12th day of August, 2008, a copy of the foregoing "DEFENDANT'S SECOND UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME" 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. The parties may access this filing through the Court's system.

s/ Sean B. McNamara