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

Case 1:05-cv-00551-LJB

Document 15

Filed 11/28/2005

Page 1 of 3

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 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 December 12, 2005, within which to file the joint preliminary status report ("JPSR"). November 28, 2005. The JPSR is due on or before

This is our second request for an enlargement

of time for this purpose, the Court having granted an enlargement of 21 days. Counsel for plaintiff, HM2 Corporation ("HM2") has

authorized us to state that HM2 opposes this motion. Counsel for HM2 offered to prepare the initial draft JPSR, and we expect to receive the initial draft soon. However, it has

not yet arrived, and the deadline for filing is today. The full enlargement of time requested is needed. We cannot

be sure when HM2 will provide the draft JPSR, or when HM2 will provide information for any JPSR that we may draft. In addition,

time is needed for review of the draft JPSR by agency counsel and by supervisors at the Department of Justice.

Case 1:05-cv-00551-LJB

Document 15

Filed 11/28/2005

Page 2 of 3

For the reasons stated above, we respectfully request that our unopposed motion for an enlargement of time be granted. Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director S/ Kathryn A. Bleecker KATHRYN A. BLEECKER 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: 202-307-6289 Fax: 202-514-7969 November 28, 2005 Attorneys for Defendant

-2-

Case 1:05-cv-00551-LJB

Document 15

Filed 11/28/2005

Page 3 of 3

CERTIFICATE OF FILING I hereby certify that on November 28, 2005, a copy of the foregoing "DEFENDANT'S 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