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

Case 1:05-cv-00891-MBH

Document 13

Filed 02/07/2006

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS BONDCOTE CORPORATION, a Virginia corporation, d/b/a BONDCOTE ROOFING SYSTEMS, Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) ) )

No. 05-891C (Judge Horn)

DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME Defendant respectfully requests the Court to enlarge by 30 days, to and including March 9, 2006, the time within which the parties must file the joint preliminary status report. The joint

preliminary status report is presently due on February 7, 2006, the Court having granted defendant's previous unopposed motion for a 29-day enlargement. This is defendant's second request for Plaintiff does not

an enlargement of time for this purpose. oppose this motion.

Plaintiff's settlement offer has been accepted by the authorized representative of the Attorney General, and Government counsel has drafted a proposed settlement agreement and sent it to plaintiff's counsel. Once the parties have executed the

settlement agreement and satisfied the conditions in the agreement, they will file a joint stipulation to dismiss this litigation. The time requested is necessary, therefore, for the

parties to complete these actions.

Case 1:05-cv-00891-MBH

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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 DAVID M. COHEN Director /s Jeanne E. Davidson JEANNE E. DAVIDSON Deputy Director /s Thomas D. Dinackus THOMAS D. DINACKUS Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L Street, N.W. Washington, DC 20530 Tele: (202) 307-6289 Fax: (202) 514-7969 Attorneys for Defendant February 7, 2006

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Case 1:05-cv-00891-MBH

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Filed 02/07/2006

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NOTICE OF FILING I hereby certify that on February 7, 2006, a copy of the foregoing "DEFENDANT'S UNOPPOSED MOTION FOR 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. the Court's system. Parties may access this filing through

/s Thomas D. Dinackus