Free Motion for Leave to File Out of Time - District Court of Federal Claims - federal

Case 1:06-cv-00103-LJB

Document 7

Filed 06/05/2006

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS

LYDIA Y. BAGLEY, et al, Plaintiffs, v. UNITED STATES OF AMERICA, Defendant.

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No. 06-103C (Judge Lynn J. Bush)

JOINT MOTION FOR LEAVE TO FILE JOINT STATUS REPORT OUT OF TIME The parties respectfully request leave to file the attached Joint Preliminary Status Report ("JPSR") out of time. The JPSR was due to be filed on Friday, June 2, 2006. On that date,

plaintiffs' counsel attempted to contact Government counsel by telephone, to discuss the preparation and filing of the JPSR. Government counsel, however, was on leave that day. Therefore, counsel for the parties were unable to complete and file the JPSR until Monday, June 5, 2006. For the foregoing reasons, the parties respectfully request that our motion for leave to file the JPSR out of time be granted. Respectfully submitted, PETER D. KEISLER Assistant Attorney General

s/Jules Bernstein JULES BERNSTEIN Bernstein & Lipsett, P.C. 1920 L Street, N.W. Suite 303 Washington, D.C. 20036

s/David M. Cohen DAVID M. COHEN Director

Case 1:06-cv-00103-LJB

Document 7

Filed 06/05/2006

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OF COUNSEL: LINDA LIPSETT Tel: (202) 296-1798 Fax: (202) 296-7220

EDGAR N. JAMES James & Hoffman, P.C. 1101 17th Street, N.W. Suite 510 Washington, D.C. 20036 Tel: (202) 496-0500 Fax: (202) 496-0555 Attorneys for Plaintiffs Dated: June 5, 2006 Filed Electronically with the consent of Attorneys for Plaintiff

s/Shalom Brilliant SHALOM BRILLIANT Senior Trial Counsel Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 1100 L Street, N.W. Washington, D.C. 20530 Tel: (202) 305-7561 Fax: (202) 305-7643 Attorneys for Defendant

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