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

Case 1:05-cv-00608-ECH

Document 32

Filed 05/24/2006

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS FRANCISCO JAVIER RIVERA AGREDANO ) and ALFONSO CALDERON LEON, ) ) Plaintiffs, ) v. ) ) THE UNITED STATES, ) ) Defendant. )

No. 05-608C (Judge Hewitt)

DEFENDANT'S MOTION FOR AN ENLARGEMENT OF TIME Defendant respectfully requests an enlargement of time of 31 days, to and including June 30, 2006, within which to file the parties joint preliminary status report ("JPSR"). The parties' JPSR currently is due May 30, 2006. This is defendant's first request for an enlargement of time for this purpose. This request for enlargement is needed because new counsel of record for the defendant was recently assigned this case, and he needs the time afforded by the enlargement to review the files in the case, discuss the case with agency counsel, and prepare appropriate responses to the questions set forth in a JPSR.1 Counsel for defendant has discussed this motion with counsel for plaintiff, Ms. Theresa Trucchi, and she does not object to this motion. For these reasons, defendant respectfully requests that the Court grant its motion for an enlargement of time. Respectfully submitted, PETER D. KEISLER Assistant Attorney General

1

Government counsel filed his notice of appearance on May 8, 2006.

Case 1:05-cv-00608-ECH

Document 32

Filed 05/24/2006

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DAVID M. COHEN Director

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

s/ DOUGLAS K. MICKLE DOUGLAS K. MICKLE Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit, 8th Floor 1100 L St., N.W. Washington, D.C. 20530 Tel: Fax: May 24, 2006 (202) 307-0383 (202) 307-7988

Attorneys for Defendant

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Case 1:05-cv-00608-ECH

Document 32

Filed 05/24/2006

Page 3 of 3

CERTIFICATE OF FILING I hereby certify that on May 24, 2006, a copy of the foregoing "MOTION FOR ENLARGEMENT" 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/ Douglas K. Mickle DOUGLAS K. MICKLE