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

Case 1:05-cv-00966-LAS

Document 12

Filed 01/30/2006

Page 1 of 3

IN THE UNITED STATES COURT OF FEDERAL CLAIMS __________________________________________ GOVERNMENT TELECOMMUNICATIONS, ) INC. ) ) Plaintiff, ) ) v. ) No. 05-966C ) (Senior Judge Smith) THE UNITED STATES, ) ) Defendant. ) ) PLAINTIFF'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME TO FILE JOINT PRELIMINARY STATUS REPORT Pursuant to Rules 6(b) and 6.1 of the Rules of the United States Court of Federal Claims, Plaintiff Government Telecommunications, Inc. (GTI) moves the Court for an enlargement of time of thirty (30) days, to and including March 2, 2006, within which the parties are to file their Joint Preliminary Status Report (JPSR) in the instant matter. The JPSR presently is scheduled to be filed by January 31, 2006. This is GTI's first request for an enlargement of time for this purpose. Defendant, the United States, has authorized GTI to represent that Defendant does not oppose this request for an enlargement of time. Plaintiff seeks this enlargement due to the unusually busy travel schedule of Plaintiff's lead counsel during the past two weeks. Specifically, Plaintiff's lead counsel was out of the country on client business during the week of January 19, 2006 and was in Las Vegas during the week of January 23, 2006 to teach two seminars for Federal Publications Seminars, Inc. on Government contracts matters. Earlier this month, counsel for both parties relaxed the pace of discovery while representatives for the parties conducted high-level settlement discussions. For

Case 1:05-cv-00966-LAS

Document 12

Filed 01/30/2006

Page 2 of 3

those periods when he has not been traveling, lead counsel for Plaintiff has been actively pursuing six matters for other clients during January 2006. For the foregoing reasons, Plaintiff respectfully requests that the Court grant an enlargement of time of thirty (30) days, to and including March 2, 2006, within which the parties may file their JPSR.

Respectfully submitted, Dated: January 30, 2006 s/ John C. Person John C. Person, Esquire PERSON & CRAVER LLP 1801 K Street, NW Washington, DC 20006 (202) 466-4434 - phone (202) 466-4416 - fax Attorneys for Plaintiff

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Case 1:05-cv-00966-LAS

Document 12

Filed 01/30/2006

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that on this 30th day of January 2006, I served Lauren S. Moore, Attorney-at-Law, Defendant's counsel, with the following document by filing it electronically in accordance with the Court's CM/ECF rules and guidelines: PLAINTIFF'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME TO FILE JOINT PRELIMINARY STATUS REPORT.

s/ John C. Person

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