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

Case 1:05-cv-00751-NBF

Document 20

Filed 06/29/2006

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS CINCINNATI INSURANCE COMPANY, Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 05-751C Judge Firestone

DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME OUT-OF-TIME Defendant respectfully requests the Court to grant an enlargement of time of 15 days, to and including July 7, 2006, within which to file the parties' joint status report. In accordance with the Court's order dated June 2, 2006, the parties' joint status report was due on June 22, 2006. Counsel for plaintiff has informed counsel for the defendant that he does not oppose this motion. No previous enlargements of time for this purpose have been requested or granted. Counsel for the defendant requests the enlargement of time out-of-time because counsel for the parties have both been traveling and have been unable to adequately address how best to resolve this litigation and to file our joint status report. Counsel for the Government unsuccessfully attempted to contact counsel for the plaintiff on or about June 15, 2006, to discuss the joint status report as she was scheduled to be out of the office June 19 through June 23. As a result, counsel for the parties did not have any communication until June 26, 2006. At that time, counsel for the plaintiff advised that he was preparing for a trial and would be out of town the remainder of that week, through June 30, 2006.

Case 1:05-cv-00751-NBF

Document 20

Filed 06/29/2006

Page 2 of 2

For the foregoing reasons, we respectfully request the Court to grant defendant's motion for an enlargement of time. Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director s/ Donald E. Kinner DONALD E. KINNER Deputy Director s/ Doris S. Finnerman DORIS S. FINNERMAN Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L Street, N.W. Washington, D.C. 20530 Department of Justice Tel: (202) 307-0300 Fax: (202) 305-7643 Attorneys for Defendant June 29, 2006

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