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

Case 1:05-cv-00410-MMS

Document 38

Filed 02/26/2007

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, the parties respectfully request an enlargement of time of two days, through and including February 28, 2007, within which the parties may file their joint status report. The joint status report is currently due on February 26, 2007. This is our first request for an enlargement of time for this joint status report. Counsel for the Government could not reach Mr. Lopez-Velazquez to determine whether plaintiff is opposed to this motion. This request for enlargement is necessary because, although the parties have exchanged drafts of the status report, the Government identified additional changes to the joint status report that may be necessary on February 26, 2007. In order to provide sufficient time for counsel for Mr. Lopez-Velazquez to review these suggested changes, we respectfully request that the Court grant an enlargement of two days, through and including February 28, 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 38

Filed 02/26/2007

Page 2 of 2

JEANNE E. DAVIDSON Acting Director s/ Todd M. Hughes TODD M. HUGHES Assistant 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 February 26, 2007 Attorneys for Defendant