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

Case 1:05-cv-00410-MMS

Document 45

Filed 08/13/2007

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS MARIO R. LOPEZ-VELAZQUEZ, Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 05-410C (Chief Judge Damich)

DEFENDANT'S MOTION TO ENLARGE Pursuant to Rule 6(b) of the Rules of the United States Court of Federal Claims, defendant, the United States, respectfully request an enlargement of time of seven days, through and including August 20, 2007, within which the parties may file their joint status report. The joint status report is currently due on August 13, 2007. This is our first request for an enlargement of time for this joint status report. Government counsel could not reach counsel for Mr. Lopez-Velazquez to determine whether plaintiff is opposed to this motion. This request for enlargement is necessary because Government counsel has not been able to reach counsel for Mr. Lopez-Velazquez to coordinate the preparation and filing of the joint status report. In order to provide sufficient time for counsel for the parties to confer and prepare a joint status report, we respectfully request that the Court grant an enlargement of seven days, through and including August 20, 2007, within which the parties may file their joint status report.

Respectfully submitted, PETER D. KEISLER. Assistant Attorney General

Case 1:05-cv-00410-MMS

Document 45

Filed 08/13/2007

Page 2 of 2

JEANNE E. DAVIDSON Director s/ Todd M. Hughes TODD M. HUGHES Deputy Director s/ Michael J. Dierberg MICHAEL J. DIERBERG Trial Attorney Department of Justice Civil Division Commercial Litigation Branch 1100 L. Street, NW Attn: Classification Unit 8th Floor Washington, D.C. 20530 Tel: (202) 353-0536 Fax: (202) 305-7643 August 13, 2007 Attorneys for Defendant