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

Case 1:05-cv-00914-LB

Document 9

Filed 02/28/2006

Page 1 of 5

IN THE UNITED STATES COURT OF FEDERAL CLAIMS K-CON BUILDING SYSTEMS, INC., Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 05-914C (Judge Block)

JOINT MOTION FOR AN ENLARGEMENT OF TIME Defendant, the United States, and plaintiff, K-Con Building Systems, Inc., respectfully request an enlargement of time of 21 days, to and including March 27, 2006, within which to file their Joint Preliminary Status Report ("JPSR"). currently is due to be filed March 6, 2006. The parties' JPSR This is the parties'

first request for an enlargement of time for this purpose. The parties have begun the process of drafting a JPSR and currently are discussing issues required to be addressed in the JPSR. Plaintiff has filed two additional actions in this Court

and the parties are attempting to reach an agreement regarding how best to proceed with discovery in all three actions. This

requested enlargement of time is required so that counsel for the parties, and agency counsel, may have sufficient time to discuss and resolve these issues as they pertain to the three cases, and to finalize the parties JPSR.

Case 1:05-cv-00914-LB

Document 9

Filed 02/28/2006

Page 2 of 5

Once these issues are resolved, additional time is necessary so that defendant's counsel may have a sufficient opportunity to submit the JPSR for review by appropriate Department of Justice officials, make any necessary changes or additions, and obtain final approval from counsel for plaintiff. For these reasons, the parties respectfully requests that the Court grant their joint motion for an enlargement of time.

-2-

Case 1:05-cv-00914-LB

Document 9

Filed 02/28/2006

Page 3 of 5

Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director s/ Bryant G. Snee BRYANT G. SNEE Assistant Director OF COUNSEL: AUDREY ROH Department of Homeland Security U.S. Coast Guard s/ David B. Stinson DAVID B. STINSON Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor, 1100 L St. Washington, D.C. 20530 Tele: (202) 307-0163 Fax: (202) 514-8624 Attorneys for Defendant

February 28, 2006

-3-

Case 1:05-cv-00914-LB

Document 9

Filed 02/28/2006

Page 4 of 5

s/ William A. Scott William A. Scott 775 St. Andrews Blvd. Charleston, South Carolina 29407 Tele: (843) 556-5656 Fax: (843) 556-5635 Attorney for Plaintiff

-4-

Case 1:05-cv-00914-LB

Document 9

Filed 02/28/2006

Page 5 of 5

CERTIFICATE OF FILING I hereby certify that on February 28, 2006, a copy of the foregoing "JOINT 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. system. s/ David B. Stinson DAVID B. STINSON Parties may access this filing through the Court's