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

Case 1:05-cv-00946-TCW

Document 10

Filed 01/18/2006

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS CHEROKEE MEDICAL SERVICES, LLC, Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 05-946C (Judge Hewitt)

DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME Defendant respectfully requests an enlargement of time of seven calendar days, to and including January 27, 2006, for the parties to file their Joint Preliminary Status Report ("JPSR"). The JPSR is presently due January 20, 2006. This is the first request for an enlargement of time for this matter. Government counsel has discussed this matter with plaintiff's counsel and represents that plaintiff does not oppose the Court's granting the Government the requested enlargement of time. The additional time is requested so that the parties may adequately confer upon the JPSR's contents prior to its filing. Lead counsel for plaintiff, Mr. Cundra, is presently in Africa and will not return until the week of January 23, 2006. Although Mr. Cundra's co-counsel, Ms. Gluck, is available (she provided consent for this motion), it is believed that the parties and the Court will be better served by a JPSR crafted with Mr. Cundra's input. For the foregoing reasons, defendant respectfully requests that the Court grant this unopposed motion for an enlargement of time. Respectfully submitted, PETER D. KEISLER Assistant Attorney General

Case 1:05-cv-00946-TCW

Document 10

Filed 01/18/2006

Page 2 of 2

DAVID M. COHEN Director

s/ Donald E. Kinner DONALD E. KINNER Assistant Director

s/ J. Reid Prouty J. REID PROUTY Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor, 1100 L Street, N.W. Washington, D.C. 20530 Tele: (202) 305-7586 Fax: (202) 514-7969 January 18, 2006 Attorneys for Defendant