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

Case 1:05-cv-00840-MMS

Document 99

Filed 03/31/2008

Page 1 of 3

IN THE UNITED STATES COURT OF FEDERAL CLAIMS ) ) Plaintiffs, ) ) v. ) ) UNITED STATES ) ) Defendant, ) ) and ) ) WEEKS MARINE, INC., ) ) Intervenor-Defendant.) FISHERMAN'S HARVEST, INC., et al.,

No. 05-0840 C and No. 05-1044C (CONSOLIDATED) (Judge Sweeney)

DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME TO FILE JOINT STATUS REPORT Pursuant to Rule 6 of the Rules of the United States Court of Federal Claims, defendant, the United States respectfully requests that the Court enlarge the deadline for the parties to file a joint status report by seven days. Pursuant to this Court's January 28, 2008 order, the deadline is currently March 31, 2008. This is our first request for enlargement for this purpose. On March 28, 2008, David Bernsen, counsel for plaintiffs, indicated that all plaintiffs' counsel would consent to this motion. Additionally, on that same date, Michael Bowdoin, counsel for defendant-intervenor, Weeks Marine, Inc., indicated that his client would consent to this motion. The requested enlargement is due to the continuing difficulty in coordinating the schedules of five attorneys of record. Although the parties have begun preparation of the joint status report, counsel plan to address several issues during a conference call. Due to various schedule conflicts, the parties now plan to hold the conference call on Tuesday, April 1, 2008. Thus, defendant respectfully requests that this Court enlarge the deadline for the parties to file a

Case 1:05-cv-00840-MMS

Document 99

Filed 03/31/2008

Page 2 of 3

joint status report by seven days, to permit the parties to discuss the outstanding issues and prepare the joint status report. Respectfully submitted, JEFFREY S. BUCHOLTZ Acting Assistant Attorney General JEANNE E. DAVIDSON Director

s/ Patricia M. McCarthy PATRICIA M. McCARTHY Assistant Director

s/ David D'Alessandris DAVID D'ALESSANDRIS Department of Justice Civil Division Commercial Litigation Branch 1100 L. Street, NW 8th Floor Washington, DC 20530 March 31, 2008 Attorneys for the United States

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Case 1:05-cv-00840-MMS

Document 99

Filed 03/31/2008

Page 3 of 3

CERTIFICATE OF FILING I hereby certify that on March 31, 2008, a copy of the forgoing "DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME TO FILE JOINT STATUS REPORT" 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. Parties may access this filing through the Court's system.

s/ David D'Alessandris