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

Case 1:05-cv-00563-LMB

Document 46

Filed 03/08/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS COLLINS NATIONAL, a limited partnership, and COLLINS DEVELOPMENT CO., a California corporation as General Partner Plaintiffs, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) ) )

No. 05-563C (Judge Baskir)

DEFENDANT'S MOTION FOR ENLARGEMENT OF TIME Pursuant to Rule 6(b)(1) of the Rules of the United States Court of Federal Claims ("RCFC"), defendant, the United States, respectfully requests a 14 day enlargement of time, to and including March 22, 2007, within which to file the joint status report. The parties' joint status report is currently due on March 8, 2007. This is either parties' first request for an enlargement of time for this purpose. Plaintiffs' counsel has represented that plaintiffs do not oppose the motion. The enlargement of time is necessary because, although the parties have begun preparation of the joint status report, counsel for defendant has been out of the office sick since Tuesday, March 6, 2007. Thus, the parties have not completed the joint status report. Moreover, counsel for defendant, Nancy Kim, will be leaving her position at the Department of Justice, effective the week of March 12, 2007. Therefore, the new attorney assigned to this case will need the additional time to coordinate with counsel for plaintiff and prepare and file the joint status report. For the foregoing reasons, defendant respectfully requests that the Court grant this motion for an enlargement of time of 14 days, to and including March 22, 2007, within which to file the

Case 1:05-cv-00563-LMB

Document 46

Filed 03/08/2007

Page 2 of 3

joint status report. Respectfully submitted, PETER D. KEISLER Assistant Attorney General JEANNE E. DAVIDSON Director s/ Bryant G. Snee BRYANT G. SNEE Assistant Director s/ Nancy M. Kim/ s/ Lauren S. Moore NANCY M. KIM Trial Attorney Commercial Litigation Branch Civil Division U.S. Department of Justice Attn: Classification Unit, 8th Floor 1100 L Street, N.W. Washington, D.C. 20530 Tel: (202) 353-0546 Fax: (202) 514-8640 Attorneys for Defendant March 8, 2007

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Case 1:05-cv-00563-LMB

Document 46

Filed 03/08/2007

Page 3 of 3

CERTIFICATE OF ELECTRONIC FILING I hereby certify that on MARCH 8, 2007, a copy of "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, and that the parties may access this filing through the Court's system. /s/ Lauren S. Moore

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