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

Case 1:05-cv-01185-MCW

Document 11

Filed 04/25/2006

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS GARY NOLAN and, RICARDO SERRANO, Plaintiffs, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) )

No. 05-1185C (Judge Williams)

DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME Pursuant to Rule 6(b)(1) of the Rules of the United States Court of Federal Claims ("RCFC"), defendant, the United States, respectfully requests a 30-day enlargement of time, to and including May 26, 2006, within which to file a joint preliminary status report. The joint preliminary status report is currently due on April 28, 2006. This is defendant's first request for enlargement of time for this purpose. Plaintiff's counsel has represented that he does not oppose this motion. The enlargement is requested because the parties would like additional time to discuss the possibility of setting this case without the need for further litigation. The parties are currently in the process of obtaining additional information that is necessary to furthering settlement discussions. Counsel for the parties have agreed to discuss the possibility of settlement over the telephone on April 28, 2006. For the foregoing reason, defendant respectfully requests that the Court grant this motion for an enlargement of time of 30 days, to and including May 26, 2006, within which to file a joint preliminary status report.

Case 1:05-cv-01185-MCW

Document 11

Filed 04/25/2006

Page 2 of 2

Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director s/ Todd M. Hughes TODD M. HUGHES Associate Director

s/ Nancy M. Kim NANCY M. KIM Trial Attorney Commercial Litigation Branch Civil Division U.S. Department of Justice Attn: Classification Unit, 8th Floor 1100 L Street, N.W. Washington, D.C. 20530 Tel: (202) 353-0546 Fax: (202) 514-8640 Attorneys for Defendant April 25, 2006