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

Case 1:06-cv-00113-MBH

Document 35

Filed 05/25/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS OAK ENVIRONMENTAL CONSULTANTS, INC., Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) )

No. 06-113C (Judge Horn)

DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME FOR THE PARTIES TO FILE THEIR SUPPLEMENTAL JOINT STIPULATIONS OF FACT AND SUPPLEMENTAL APPENDIX Pursuant to United States Court of Federal Claims Rule 6.1, defendant, the United States, respectfully requests an enlargement of time of seven days, from May 25, 2007, through and including June 1, 2007, for the parties to file their supplemental joint stipulations of fact ("supplemental facts") and supplemental appendix. This is our first request for an Plaintiff's counsel does

enlargement of time for this purpose. not oppose this motion.

This action arises from a Navy construction contract. Plaintiff has prepared a draft of the supplemental facts. Government counsel currently intends to propose minor changes. However, a short enlargement is required to allow Government counsel to confer with agency counsel, who currently is out of the office. Further, the Government also will need to discuss Accordingly, we

the proposed changes with plaintiff's counsel.

respectfully request a brief enlargement of time to enable the parties to finalize their supplemental joint facts.

Case 1:06-cv-00113-MBH

Document 35

Filed 05/25/2007

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CONCLUSION For the foregoing reasons, defendant, the United States, respectfully requests that this Court grant an enlargement of time, through and including June 1, 2007, for the parties to file their supplemental facts and supplemental appendix. Respectfully submitted, PETER D. KEISLER Assistant Attorney General JEANNE E. DAVIDSON Director s/Steven J. Gillingham STEVEN J. GILLINGHAM Assistant Director s/Richard P. Schroeder RICHARD P. SCHROEDER Trial Attorney Commercial Litigation Branch Civil Division U.S. Department of Justice Attn: Classification Unit Eighth Floor 1100 L Street, N.W. Washington, D.C. 20530 Tele: (202) 305-7562 Attorneys for Defendant May 25, 2007

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Case 1:06-cv-00113-MBH

Document 35

Filed 05/25/2007

Page 3 of 3

CERTIFICATE OF FILING I hereby certify under penalty of perjury that on this 25th day of May 2007, a copy of the foregoing "DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME FOR THE PARTIES TO FILE THEIR SUPPLEMENTAL JOINT STIPULATIONS OF FACT AND SUPPLEMENTAL APPENDIX" 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/Richard P. Schroeder

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