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

Case 1:05-cv-00551-LJB

Document 58

Filed 09/05/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS HM2 CORPORATION, d/b/a HM2 CONSTRUCTORS AND FABRICATORS, Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) )

No. 05-551C (Judge Bush)

DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Defendant, the United States, respectfully requests the Court to grant an enlargement of time of 14 days, to and including September 19, 2008, within which to file the joint status report required by the Court's order, dated August 20, 2008. This is our first request for an enlargement of time for Counsel for the plaintiff, HM2 Corporation ("HM2")

this purpose.

has authorized us to state that HM2 does not oppose this motion. The parties have engaged in several conversations concerning the joint status report during the past two weeks. communications have been cordial and productive. Those However, as

discussions have gone forward, the topics have evolved, and so the decisions that must be made have changed. Additional time is

needed to reach consensus on various important matters before an appropriate joint status report (reflecting the mature understandings of the parties) may be filed. The full amount of additional time requested is needed. Counsel for the parties must consult with clients, and complete agreements with each other. In addition, time is needed for

Case 1:05-cv-00551-LJB

Document 58

Filed 09/05/2008

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review of the draft joint status report by agency counsel and by supervisors at the Department of Justice. For the reasons stated above, we respectfully request that our unopposed motion for an enlargement of time be granted. Respectfully submitted, GREGORY G. KATSAS Assistant Attorney General JEANNE E. DAVIDSON Director S/ Harold D. Lester, Jr. HAROLD D. LESTER, JR. Assistant Director S/ James W. Poirier JAMES W. POIRIER Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor, 1100 L St, N.W Washington, D.C. 20530 Tele: 202-616-0856 Fax: 202-514-7969 September 5, 2008 Attorneys for Defendant

-2-

Case 1:05-cv-00551-LJB

Document 58

Filed 09/05/2008

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CERTIFICATE OF FILING I hereby certify that on September 5, 2008, a copy of the foregoing "DEFENDANT'S UNOPPOSED MOTION FOR AN 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 Court's system. S/ James W. Poirier Parties may access this filing through