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

Case 1:02-cv-00483-FMA

Document 36

Filed 06/21/2005

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS

FORD MOTOR COMPANY AND AFFILIATES, Plaintiff, v. THE UNITED STATES, Defendant.

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No. 02-483 T The Honorable Francis M. Allegra

_________________ MOTION FOR ENLARGEMENT OF TIME _________________

Defendant, the United States, on behalf of itself and plaintiff 1/ in the above-captioned case, and in accordance with Rules 6(b) and 6.1 of the Rules of the United States Court of Federal Claims, and the Court's Special Procedures Order of May 31, 2002, respectfully moves the Court for an enlargement of time of 30 days, from June 21, 2005, to and including July 21, 2005, within which the parties are to file a joint stipulation of facts, and a similar enlargement of time of 30 days, from July 21, 2005, to and including August 20, 2005, within which plaintiff is to file a motion for summary judgment. Counsel for the parties met in Washington on June 15 to discuss this case, to determine whether any possibility of settlement exists, and to discuss the substantive issues presented with a view toward

While this document has been executed only by defendant's attorneys, it was reviewed and approved by plaintiff's counsel as a joint filing.

1/

Case 1:02-cv-00483-FMA

Document 36

Filed 06/21/2005

Page 2 of 2

finalizing a stipulation of facts. In the course of those discussions, it became apparent to defendant's trial attorney that there exist aspects of this case -- which presents esoteric questions of the computation of interest prior to 1982 -- that have not been fully understood. It is his view that the possibility of settlement still exists, but that additional time is necessary to explore these new ideas and either to solicit a settlement, or finalize a stipulation upon which the case can be resolved by the Court. The time requested herein is necessary to complete this task. Respectfully submitted.

s/ W. C. Rapp W.C. RAPP Attorney of Record United States Department of Justice Tax Division Court of Federal Claims Section Post Office Box 26 Ben Franklin Post Office Washington, DC 20044 Voice: (202) 307-0503 Fax: (202) 514-9440 Email: [email protected] EILEEN J. O'CONNOR Assistant Attorney General MILDRED L. SEIDMAN Chief, Counsel of Federal Claims Section

June 21, 2005

s/ Mildred L. Seidman Of Counsel