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

Case 1:05-cv-00612-CCM

Document 29

Filed 03/26/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS SUSAN CARSON, Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

05-612C (Judge Block)

DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME Pursuant to Rule 6.1 of the Rules of the Court of Federal Claims, defendant respectfully requests that the Court enlarge by 30 days, to and including April 27, 2007, the deadline for filing the parties' joint status report proposing how they would like to proceed in the above-captioned matter. The joint status report is currently due on March 28, 2007. Defendant has consulted with counsel for plaintiff, and counsel for plaintiff has represented that plaintiff does not oppose this motion for enlargement of time. The parties completed fact discovery in this case on March 7, 2007. Counsel for defendant entered her appearance in this case on March 15, 2007, replacing prior counsel, who resigned from the Government, as counsel of record. The requested enlargement of time is necessary for counsel for defendant to familiarize herself with the factual and legal issues in the case and to review the discovery materials to determine how defendant would like to proceed. Counsel for defendant cannot make an informed joint proposal to the Court until she has had the opportunity to become sufficiently familiar with the case.

Case 1:05-cv-00612-CCM

Document 29

Filed 03/26/2007

Page 2 of 3

For the foregoing reasons, defendant respectfully requests that the Court grant this motion for enlargement of time of 30 days, to and including April 27, 2006, within which to file the joint preliminary status report.

Respectfully submitted, PETER D. KEISLER Assistant Attorney General JEANNE E. DAVIDSON Director

s/ Kathryn A. Bleecker KATHRYN A. BLEECKER Assistant Director

s/ Tara Kilfoyle TARA KILFOYLE Trial Attorney Commercial Litigation Branch Civil Division 1100 L St., N.W. Attn: Classification Unit 8th Floor Washington, D.C. 20530 Tele: (202) 305-1709 Fax: (202) 307-0972

March 26, 2007

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Case 1:05-cv-00612-CCM

Document 29

Filed 03/26/2007

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that on this 26th day of March 2007, a copy of the foregoing "DEFENDANT'S 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 parties may access this filing through the Court's system.

s/ Tara Kilfoyle