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

Case 1:05-cv-00490-TCW

Document 28

Filed 05/12/2006

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS SSA MARINE, INC., Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 05-490C (Chief Judge Damich)

DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME Defendant respectfully requests the Court enlarge by 14 days, to and including June 9, 2006, the date by which the Government's expert report must be completed. The Government's

expert report is presently due to be completed by May 26, 2006. This is defendant's first request for an enlargement of time for this purpose. Plaintiff's counsel has informed Government

counsel that plaintiff does not oppose this motion. As explained in greater detail in the declaration that is included in the appendix to this motion, the requested enlargement is necessary in order for the Government's expert to complete his analysis of the documents and issues in this matter, and prepare his report. As part of this effort, the Government

will be taking a deposition pursuant to RCFC 30(b)(6) with regard to certain aspects of plaintiff's claim. The Government's RCFC

30(b)(6) deposition has been tentatively scheduled for May 26, 2006. For the foregoing reasons, defendant respectfully requests that the Court grant this unopposed motion for an enlargement of

Case 1:05-cv-00490-TCW

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Filed 05/12/2006

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time. Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director /s Bryant G. Snee BRYANT G. SNEE Assistant Director /s Thomas D. Dinackus THOMAS D. DINACKUS Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L Street, N.W. Washington, DC 20530 Tele: (202) 307-6289 Fax: (202) 514-7969 Attorneys for Defendant OF COUNSEL: JOHN B. ALUMBAUGH PETER E. YOUNG U.S. Agency for International Development May 12, 2006

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Case 1:05-cv-00490-TCW

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Filed 05/12/2006

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NOTICE OF FILING I hereby certify that on May 12, 2006, a copy of the foregoing "DEFENDANT'S UNOPPOSED 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. the Court's system. Parties may access this filing through

/s Thomas D. Dinackus