Free Motion to Amend Schedule - District Court of Federal Claims - federal

Case 1:05-cv-01042-CFL

Document 42

Filed 07/24/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS DALLES IRRIGATION DISTRICT, Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 05-1042C (Judge Lettow)

DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME FOR MEETING OF COUNSEL AND TO AMEND SCHEDULING ORDER Pursuant to the Court's scheduling order of April 30, 2007, the final pre-trial conference will be held on November 6, 2007. Accordingly, pursuant to Appendix A of this Court's rules, the meeting of counsel must occur by September 4, 2007. Defendant seeks to enlarge that deadline by 14 days, to and including September 18, 2007. Additionally, if the Court grants this enlargement, defendant respectfully moves to amend the scheduling order to the extent that the September 10, 2007 status conference should be rescheduled until September 25, 2007, or such other time that is convenient for the Court. Plaintiff's counsel concurs with the proposed dates, and does not object to this request. The additional time is necessary because defendant's counsel has answers due in the following other cases: (1) CCS Industrial Sales, Inc. v, United States, No. 07-326C (Fed. Cl.), on July 30, 2007; (2) Great Lakes Dredge & Dock Co. v. United States, No. 07-218C (Fed. Cl.), on August 16, 2007; (3) Pennsauken Senior Towers Urban Renewal Assoc., LLC v. United States, No. 07-174C (Fed. Cl.), on August 21, 2007; and (4) Securitas Gmbh Werkschutz v. United States, Nos. 07-255C/256C/257C (Fed. Cl.) (three cases requiring three separate answers), on August 24, 2007. In addition to these cases, this Court directed that the Government treat the case of TMI Mgmt. Systems, Inc. v. United States, No. 07-407C (Fed. Cl.),

Case 1:05-cv-01042-CFL

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Filed 07/24/2007

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on an expedited schedule, akin to a bid protest case, and file its brief by August 31, 2007. The Court will hold argument shortly thereafter. Government counsel will also be traveling to the National Advocacy Training Center for a course from September 10 through 12, 2007. After returning from the course and oral argument, Government counsel will travel to Portland, Oregon, for the meeting of counsel. Respectfully submitted, PETER D. KEISLER Assistant Attorney General JEANNE E. DAVIDSON Director s/ Franklin E. White, Jr. FRANKLIN E. WHITE, JR. Assistant Director s/ Armando Rodriguez-Feo ARMANDO RODRIGUEZ-FEO Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit, 8th Floor 1100 L St., NW Washington, D.C. 20530 Tel: (202) 307-3390 Fax: (202) 514-8624 Attorneys for Defendant July 24, 2007

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Case 1:05-cv-01042-CFL

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Filed 07/24/2007

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CERTIFICATE OF FILING I hereby certify that on this 24th day of July, 2007, a copy of the foregoing "DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME FOR MEETING OF COUNSEL AND TO AMEND SCHEDULING ORDER" 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/ Armando Rodriguez-Feo