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

Case 1:05-cv-00773-EJD

Document 12

Filed 11/18/2005

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS

No. 05-773 T (Chief Judge Damich) DAVID SUNSHINE and KELLY T. HICKEL, Plaintiffs v. THE UNITED STATES, Defendant ____________ MOTION FOR ENLARGEMENT OF TIME ____________ Pursuant to Rule 6.1 of the Rules of the United States Court of Federal Claims, defendant respectfully moves the Court for an enlargement of thirty (30) days, from December 27, 2005, to and including January 26, 2006, within which to file a joint preliminary status report. This is the first enlargement of time defendant has requested for this purpose. As good cause for its motion, defendant states that the undersigned trial attorney has significant work commitments that preclude a meaningful and productive early meeting of counsel prior to the current deadline of December 27, 2005. These commitments include substantial time assisting with the preparation of post-trial briefs in a matter pending before Judge Williams, Jade Trading v. United States, Fed. Cl. No. 03-2164T, and a long-standing commitment to attend a Department of Justice training program in South Carolina from December 5 to 15, 2005. Defendant's attorney of record spoke with plaintiffs' counsel by telephone on -1-

Case 1:05-cv-00773-EJD

Document 12

Filed 11/18/2005

Page 2 of 2

November 17, 2005, and counsel stated that plaintiffs have no objection to the requested enlargement.

Respectfully submitted,

s/ Jennifer P. Wilson JENNIFER P. WILSON Attorney of Record U.S. Department of Justice Tax Division Court of Federal Claims Section Post Office Box 26 Ben Franklin Post Office Washington, D.C. 20044 (202) 307-6495 - phone (202) 514-9440 - fax [email protected] EILEEN J. O'CONNOR Assistant Attorney General DAVID GUSTAFSON Acting Chief, Court of Federal Claims Section ROBERT J. HIGGINS Reviewer

s/ Robert J. Higgins Of Counsel November 18, 2005

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