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

Case 1:05-cv-01020-MMS

Document 62

Filed 04/02/2008

Page 1 of 4

IN THE UNITED STATES COURT OF FEDERAL CLAIMS AMERICAN INTERNATIONAL SPECIALTY LINES INSURANCE COMPANY, Plaintiff, v. UNITED STATES OF AMERICA, Defendant. ) ) ) ) ) ) ) ) ) )

No. 05-1020C Judge Margaret M. Sweeney

PLAINTIFF'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME TO FILE JOINT PRELIMINARY STATUS REPORT Plaintiff American International Specialty Lines Insurance Company ("Plaintiff" or "AISLIC"), by counsel, pursuant to Rules 6(b) and 6.1 of the Rules of the United States Court of Federal Claims ("RCFC"), respectfully requests an enlargement of time within which to file the parties' Joint Preliminary Status Report ("JPSR"). The JPSR currently is due on April 3, 2008. AISLIC requests an enlargement of 21 days to file the JPSR, through April 24, 2008. This is AISLIC's first request for an enlargement of time for the purpose of filing the JPSR. Defendant's counsel has agreed to this enlargement. The requested enlargement is needed to ensure the parties have sufficient time to agree to as much of the JPSR content as possible. AISLIC has provided a draft JPSR to Defendant. The length of the requested enlargement is due in part to counsel's conflicting schedules. Plaintiff's counsel has an opposition to a motion to dismiss due in an unrelated matter on April 18. Defense counsel will be unavailable to confer on the content of the JPSR during the week of April 14 due to previously scheduled travel to conduct discovery in an unrelated matter. For the foregoing reasons, Plaintiff AISLIC respectfully requests that the Court grant this unopposed motion for an enlargement of time to and including April 24, 2007, within which to file the parties' Joint Preliminary Status Report.

Case 1:05-cv-01020-MMS

Document 62

Filed 04/02/2008

Page 2 of 4

Respectfully submitted, s/T. Michael Guiffré T. Michael Guiffré J. Gordon Arbuckle Daniel R. Addison PATTON BOGGS LLP 2550 M Street, N.W. Washington, D.C. 20037 Telephone: (202) 457-6000 Facsimile: (202) 457-6315 Attorneys for Plaintiff American International Specialty Lines Insurance Company April 2, 2008

Case 1:05-cv-01020-MMS

Document 62

Filed 04/02/2008

Page 3 of 4

IN THE UNITED STATES COURT OF FEDERAL CLAIMS AMERICAN INTERNATIONAL SPECIALTY LINES INSURANCE COMPANY, Plaintiff, v. UNITED STATES OF AMERICA, Defendant. ) ) ) ) ) ) ) ) ) )

No. 05-1020C Judge Margaret M. Sweeney

[PROPOSED] ORDER This matter having come before the Court on Plaintiff's Unopposed Motion for an Enlargement of Time to File Joint Preliminary Status Report, this court finds just cause to GRANT same and rule as follows. Wherefore, it is hereby: ORDERED, that Plaintiff shall file the Joint Preliminary Status Report by April 24, 2008. So Ordered this _____ day of ____________, 20__.

MARGARET M. SWEENEY Judge

Case 1:05-cv-01020-MMS

Document 62

Filed 04/02/2008

Page 4 of 4

CERTIFICATE OF FILING I certify that on April 2, 2008, the foregoing motion 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/T. Michael Guiffré T. Michael Guiffré