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

Case 1:05-cv-00410-MMS

Document 32

Filed 01/10/2007

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)

JOINT 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, out of time, of three business days, to and including January 10, 2007, within which the parties may file their joint status report. The joint status report was due on January 5, 2007. This is the parties' first request for an enlargement of time for this joint status report. This request for enlargement is necessary because the parties inadvertently overlooked the deadline for filing the joint status report. Government counsel neglected to transfer the due date of the status report to counsel's tracking system, and did not realize that the parties had missed the deadline for filing the joint status report until late on January 9, 2007. For these reasons, we respectfully request that the Court grant an enlargement of three days business days, through and including January 10, 2007, within which the parties may file their joint status report.

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

Case 1:05-cv-00410-MMS

Document 32

Filed 01/10/2007

Page 2 of 2

Director s/ Gary Myers GARY MYERS 78 Clark Mill Road Weare, NH 03281 Attorney for Plaintiff 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 Attorneys for Defendant

January 10, 2007