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

Case 1:05-cv-01042-CFL

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Filed 08/31/2006

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

No. 05-1042C (Judge Lettow)

DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME Pursuant to Rule 6(b) of the Rules of the United States Court of Federal Claims, defendant, the United States, respectfully requests the Court to enlarge the deadline for the parties' joint preliminary status report ("JPSR") by eight days, to and including September 8, 2006. The JPSR currently is due August 31, 2006. This is defendant's first motion for this purpose. Counsel for defendant has contacted counsel for plaintiff regarding this motion and is authorized to state that plaintiff does not oppose this motion. This motion is necessary because of unanticipated delays experienced by the parties in coordinating and completing all of the required portions for the JPSR. These delays have rendered it impossible to complete the JPSR by the current deadline. The requested enlargement should provide the parties sufficient time to complete the JPSR.

Case 1:05-cv-01042-CFL

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Filed 08/31/2006

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In addition, consistent with the directives set forth in Appendix A to the RCFC, counsel for the parties have discussed, among other things, the scope of the discovery that will be necessary for this case and the possibility of participating in alternative dispute resolution ("ADR") proceedings. The requested enlargement will provide counsel for the parties sufficient time to continue their discussions, particularly regarding ADR proceedings. At the requested deadline, the parties will address the status of these discussions in the JPSR. Accordingly, we respectfully request the Court to grant this motion to enlarge the deadline for the parties' joint status report by eight days, to and including September 8, 2006. Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director /s/ Franklin E. White, Jr. FRANKLIN E. WHITE, JR. Assistant Director

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Case 1:05-cv-01042-CFL

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Filed 08/31/2006

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/s/ Gregory T. Jaeger GREGORY T. JAEGER Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L Street, N.W. Washington, D.C. 20005 (202) 353-7955 August 31, 2006 Attorneys for Defendant

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Case 1:05-cv-01042-CFL

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Filed 08/31/2006

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CERTIFICATE OF FILING I hereby certify that on August 31, 2006, a copy of the foregoing "DEFENDANT'S UNOPPOSED MOTION FOR 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. Parties may access this filing through the Court's system.

/s/Gregory T. Jaeger