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

Case 1:05-cv-01029-MCW

Document 8

Filed 03/10/2006

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS CALIFORNIA HUMAN DEVELOPMENT CORPORATION, Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) )

No. 05-1029C (Judge Williams)

JOINT MOTION FOR AN ENLARGEMENT OF TIME Pursuant to Rule 6(b) of the Rules of the United States Court of Federal Claims ("RCFC"), plaintiff and defendant request an enlargement of time of 21 days, to and including March 31, 2006, within which to file a joint preliminary status report ("JPSR"). The parties' JPSR is now due on March 10, 2006. This

is our first request for an enlargement of time for this purpose. Due to numerous other assignments to complete since service of the answer in this case, and recent scheduling conflicts, the parties have not yet been able to reach agreement upon a JPSR. In addition, defendant's counsel will be attending an intensive training course at the National Advocacy Center in Columbia, South Carolina, from March 13, 2006 through March 17, 2006. Therefore, we anticipate that an additional 21 days will be required to prepare and file our JPSR. For the foregoing reasons, plaintiff and defendant request that the Court grant this motion for an enlargement of time.

Case 1:05-cv-01029-MCW

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Filed 03/10/2006

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Respectfully submitted, s/ Steven D. Cundra STEVEN D. CUNDRA Hall, Estill, Hardwick, Gable, Golden & Nelson, P.C. 1120 20th Street, N.W. Suite 700, North Building Washington, D.C. 20036 Tel: (202) 973-1200 Fax: (202) 973-1212 Attorney for Plaintiff s/ Jeffrey S. Pease JEFFREY S. PEASE Trial Attorney Commercial Litigation Branch Civil Division Department of Justice 1100 L St., N.W. Attn: Classification Unit 8th Floor Washington, D.C. 20530 Tel: (202) 307-1011 Fax: (202) 514-8624 Attorneys for Defendant March 10, 2006 PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director s/ Bryant G. Snee BRYANT G. SNEE Assistant Director

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Case 1:05-cv-01029-MCW

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Filed 03/10/2006

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CERTIFICATE OF FILING

I hereby certify that on this 10th day of March, 2006, a copy of the foregoing "JOINT MOTION FOR AN 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. the Court's system. Parties may access this filing through

s/ Jeffrey S. Pease