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

Case 1:05-cv-00781-LMB

Document 14

Filed 01/06/2006

Page 1 of 4

IN THE UNITED STATES COURT OF FEDERAL CLAIMS

HUBERT BASFORD, ROXANNE BASFORD, and BEAR MOUNTAIN CONTRACTING Plaintiffs, v. THE UNITED STATES Defendant.

) ) ) ) ) ) ) ) ) ) ) )

No. 05-781C (Judge Baskir)

JOINT MOTION FOR AN ENLARGEMENT OF TIME Defendant, on behalf of both parties, respectfully requests an enlargement of time of 8 days, until January 17, to file our Joint Preliminary Status Report ("JPSR"). The JPSR is currently due on January 9, 2006 and this is our first request for an enlargement of time for this purpose. The parties have been discussing the JPSR, have exchanged drafts, and were planning on filing the JPSR on January 9. Coincidentally, defendant's counsel was provisionally planning on traveling to Missoula, Montana to interview agency witnesses and review documents related to this case during the period January 9 through 11. Defendant's counsel has finalized his travel plans and his schedule is such that he may have the

Case 1:05-cv-00781-LMB

Document 14

Filed 01/06/2006

Page 2 of 4

opportunity to meet plaintiffs' counsel in person, who also resides in Missoula. Counsel believe that such a meeting will facilitate the parties' discussion and completion of the JPSR. Additionally, we apologize to the Court for any inconvenience that might be caused by the arguably belated filing of this motion. See Special Procedures Order, para. 7., filed August 15, 2005. However, defendant's travel plans were finalized just today and, thus, we filed this motion immediately. Plaintiffs' counsel has reviewed this motion and agrees with its contents. For these reasons, the parties requests that the Court grant a unopposed motion for an 8 day enlargement of time and extend the filing date for JPSR until January 17, 2006. Respectfully submitted,

PETER D. KEISLER Assistant Attorney General s/ David M. Cohen DAVID M. COHEN Director

2

Case 1:05-cv-00781-LMB

Document 14

Filed 01/06/2006

Page 3 of 4

OF COUNSEL: Jennifer Newbold Office of Counsel Department of Agriculture

s/ Bryant G. Snee BRYANT G. SNEE Assistant Director Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor, 1100 L Street Washington, D.C. 20530 Tele: (202) 307-0282 Fax: (202) 514-8624 Attorneys for Defendant

January 6, 2006

3

Case 1:05-cv-00781-LMB

Document 14

Filed 01/06/2006

Page 4 of 4

CERTIFICATE OF FILING I hereby certify that on January 6, 2005, a copy of the foregoing "JOINT 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. Parties may access this filing through the Court's system. s/ Bryant G. Snee BRYANT G. SNEE