Free Motion for Leave to File - District Court of Federal Claims - federal

Case 1:05-cv-00528-LMB

Document 46

Filed 10/26/2006

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS TELENOR SATELLITE SERVICES, INC., Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 05-528C (Judge Baskir)

DEFENDANT'S MOTION FOR LEAVE TO FILE DISPOSITIVE MOTION Defendant, the United States, requests leave to file a dispositive motion. On September 29, 2006, the Government stated in the parties' Joint Status Report that it expected to file a dispositive motion that included briefing of the issue whether plaintiff could have avoided the costs that it seeks in this action. The Government proposed October 31, 2006, as the date for filing dispositive motions. Although the Court has not set a briefing schedule for further dispositive motions, the Government is prepared to file such a motion upon that issue by October 31, 2006. For these reasons, the Government respectfully requests leave to file a dispositive motion by October 31, 2006.

Case 1:05-cv-00528-LMB

Document 46

Filed 10/26/2006

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Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director

s/Patricia M. McCarthy PATRICIA M. MCCARTHY Assistant Director

s/Timothy P. McIlmail TIMOTHY P. MCILMAIL Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L Street, N.W. Washington, D.C. 20005 Telephone: (202) 616-0342 Facsimile: (202) 514-7965

OF COUNSEL: ONA M. HAHS Attorney-Adviser Department of State Attorneys for Defendant October 26, 2006

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Case 1:05-cv-00528-LMB

Document 46

Filed 10/26/2006

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Certificate of Filing I hereby certify that on October 26, 2006, a copy of the foregoing Defendant's Motion For Leave To File Dispositive Motion 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/Timothy P. McIlmail