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

Case 1:05-cv-00954-LAS

Document 14

Filed 02/13/2006

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS ____________ No. 05-954 T (Judge Loren A. Smith) D. GORDON POTTER, Plaintiff v. THE UNITED STATES, Defendant ____________ JOINT MOTION FOR ENLARGEMENT OF TIME ____________ Pursuant to Rule 6(b) of the Rules of the United States Court of Federal Claims, the parties respectfully move the Court for an enlargement of time of fourteen (14) days, from February 13, 2006, to and including February 27, 2006, within which to file their joint preliminary status report. This is the first enlargement of time the parties have requested for this purpose. As reason for this motion, the parties state that defendant's attorney of record prepared a draft joint preliminary status report and e-mailed the draft to plaintiff's counsel on February 8, 2006. (Defendant's attorney of record confirmed on February 8 that plaintiff's counsel received the draft and expected to be able to comply with the February13 filing deadline.) At 2:30 p.m. (E.S.T.) on February 13, 2006, however, plaintiff's counsel informed defendant's counsel that his office is preparing proposed revisions to the draft report. After receiving plaintiff's proposed revisions, defendant's counsel will need time to review the proposed changes and discuss them -1-

Case 1:05-cv-00954-LAS

Document 14

Filed 02/13/2006

Page 2 of 2

with plaintiff's counsel. In addition, after counsel have informally agreed on a revised draft, defendant's counsel will need to submit the revised joint preliminary status report for review prior to its final preparation for filing with the Court. Plaintiff's counsel has authorized defendant's counsel to sign this joint motion on his behalf. Respectfully submitted, s/Robert J. Stientjes ROBERT J. STIENTJES Gasaway & Stientjes LLP 41 S. Old Orchard Ave., Ste. B Saint Louis, MO 63119 (314) 961-3812 FAX (314) 918-7120 Attorney for Plaintiff s/Jennifer P. Wilson JENNIFER P. WILSON Attorney of Record U.S. Department of Justice Tax Division Court of Federal Claims Section Post Office Box 26 Ben Franklin Post Office Washington, D.C. 20044 (202) 307-6495 FAX (202) 514-9440 [email protected] EILEEN J. O'CONNOR Assistant Attorney General DAVID GUSTAFSON Acting Chief, Court of Federal Claims Section s/David Gustafson February 13, 2006 Of Counsel -2-