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

Case 1:05-cv-00463-LAS

Document 11

Filed 10/28/2005

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS __________________________________________ GOVERNMENT TELECOMMUNICATIONS, ) INC. ) ) Plaintiff, ) ) v. ) No. 05-463C ) (Senior Judge Smith) THE UNITED STATES, ) ) Defendant. ) ) PLAINTIFF'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME TO FILE JOINT PRELIMINARY STATUS REPORT Pursuant to Rules 6(b) and 6.1 of the Rules of the United States Court of Federal Claims, Plaintiff Government Telecommunications, Inc. (GTI) moves the Court for an enlargement of time of ten (10) days, to and including November 10, 2005, within which the parties are to file their Joint Preliminary Status Report (JPSR) in the instant matter. The JPSR presently is scheduled to be filed by October 31, 2005. This is GTI's first request for an enlargement of time for this purpose. Defendant, the United States, has authorized GTI to represent that Defendant does not oppose this request for an enlargement of time. Plaintiff seeks this enlargement so that it can fully review whether all the relevant issues before this Court have been sufficiently articulated by the draft JSPR circulated by counsel for Defendant on October 13, 2005. As the Court is aware, the instant action is a consolidation of four separate lawsuits advancing six separate claims. Plaintiff's principal reason for requesting this enlargement is that lead counsel for Plaintiff has had to focus on other matters during the past two weeks. During the week of October 10th, lead counsel for Plaintiff had to accompany his wife to a local hospital for knee surgery. This kept GTI's lead counsel from working for

Case 1:05-cv-00463-LAS

Document 11

Filed 10/28/2005

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roughly 2-1/2 days during that week. From Sunday, October 23, 2003 through Tuesday, October 25, 2003, lead counsel for Plaintiff was in Columbia, SC taking and defending depositions in UniTech Services Group, Inc. v. ENVIRO AgScience, Inc., a matter pending in local court in SC. In addition to the foregoing, counsel for Plaintiff has had to support approximately eight other ongoing Government contracts matters during these past two weeks. Notwithstanding that lead counsel for Plaintiff has worked these past two weekends, he has not had time to sufficiently focus on the draft JPSR. For the foregoing reasons, Plaintiff respectfully requests that the Court grant an enlargement of time of ten (10) days, to and including November 10, 2005, within which the parties may file their JPSR.

Respectfully submitted, Dated: October 28, 2005 s/ John C. Person John C. Person, Esquire PERSON & CRAVER LLP 1801 K Street, NW Washington, DC 20006 (202) 466-4434 - phone (202) 466-4416 - fax Attorneys for Plaintiff

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Case 1:05-cv-00463-LAS

Document 11

Filed 10/28/2005

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CERTIFICATE OF SERVICE I hereby certify that on this 28th day of October 2005, I served Lauren S. Moore, Attorney-at-Law, Defendant's counsel, with the following document by filing it electronically in accordance with the Court's CM/ECF rules and guidelines: PLAINTIFF'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME TO FILE JOINT PRELIMINARY STATUS REPORT.

s/ John C. Person

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