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

Case 1:05-cv-00915-MMS

Document 13

Filed 03/16/2006

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UNITED STATES COURT OF FEDERAL CLAIMS ***************************** CADDELL CONSTRUCTION CO., INC., for the use and benefit of HENDERSON ELECTRIC, HEAT & AIR CONDITIONING, INC., Plaintiff, No. 05-915C v. Judge Margaret M. Sweeney UNITED STATES ARMY CORPS OF ENGINEERS, Defendant. ***************************** MOTION FOR ENLARGEMENT OF TIME TO FILE JOINT PRELIMINARY STATUS REPORT Plaintiff, Caddell Construction Co., Inc., for the use and benefit of Henderson Electric, Heat & Air Conditioning, Inc. ("Henderson"), moves for an enlargement of time to file the Joint Preliminary Status Report ("JPSR") as required by RCFC Appendix A, Art. III, and states: 1. Defendant, United States Army Corps of Engineers ("COE") filed its answer and

affirmative defenses on January 27, 2006. 2. The JPSR will be due on March 17, 2006, forty-nine (49) days after COE filed its

answer and affirmative defenses. See RCFC Appendix A, Art. III.4. 3. Henderson has provided a proposed draft of the JPSR to COE, but the parties have

been unable to reach a consensus as to the final content of the JPSR. 4. Henderson has conferred with counsel for COE, and, on the basis of that conference,

represents that COE interposes no objection to this motion.

Case 1:05-cv-00915-MMS

Document 13

Filed 03/16/2006

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5.

Therefore, Henderson requests a 14-day enlargement of time to file the JPSR, to be

filed no later than March 31, 2006. WHEREFORE, Henderson requests a 14-day enlargement of time to file the JPSR, to be filed no later than March 31, 2006.

Respectfully submitted,

Dated: March 16, 2006

/s W. Robert Vezina, III W. ROBERT VEZINA, III Vezina, Lawrence & Piscitelli, P.A. 318 North Calhoun Street Tallahassee, Florida 32301 Telephone: (850) 224-6205 Facsimile: (850) 224-1353 Attorneys for Plaintiff

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