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

Case 1:05-cv-00966-LAS

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS GOVERNMENT TELECOMMUNICATIONS, INC., Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) No. 05-966C ) (Senior Judge Smith) ) ) )

DEFENDANT'S MOTION FOR AN ENLARGEMENT OF TIME Defendant respectfully requests an enlargement of time of 21 calendar days, to and including November 30, 2006, within which to file the joint status report in this case. The parties'

joint status report currently is due to be filed on November 9, 2006. This is either party's first request for an enlargement of Counsel for defendant has attempted to

time for this purpose.

contact counsel for plaintiff regarding this motion, but has not been able to reach him. The additional time is necessary because counsel for the parties have not completed their preparation of the joint status report. Specifically, on November 2, 2006, undersigned counsel

for defendant forwarded a draft of the joint status report to counsel for plaintiff, but counsel for plaintiff has not provided comments to counsel for defendant or otherwise indicated approval of the draft joint status report. Counsel for defendant has

attempted to contact counsel for plaintiff numerous times since November 2, 2006 but has not been able to reach him. Nor has

counsel for plaintiff returned counsel for defendant's telephone

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messages.

Thus, the additional time is necessary to allow the

parties to prepare and file the joint status report. For the foregoing reason, we respectfully request that our motion for an enlargement of time be granted. Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director s/ Harold D. Lester, Jr. HAROLD D. LESTER, JR. Assistant Director s/ Lauren S. Moore LAUREN S. MOORE Attorney Commercial Litigation Branch Civil Division Department of Justice 1100 L Street, N.W. Attn: Classification Unit 8th Floor Washington, D.C. 20530 Tele: (202) 307-6288 Fax: (202) 514-8640 NOVEMBER 9, 2006 Attorneys for Defendant

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CERTIFICATE OF FILING I hereby certify that on the 9th day of NOVEMBER, 2006, a copy of the foregoing "DEFENDANT'S 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. /s/ Lauren S. Moore Parties may access this filing through