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

Case 1:05-cv-00410-MMS

Document 29

Filed 12/11/2006

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 requests an enlargement of time of three days, to and including December 14, 2006, within which the parties may file their joint status report. The joint status report is currently due on December 11, 2006. This is defendant's first request for an enlargement of time for this purpose. Counsel for defendant has been unable to reach counsel for plaintiff to determine whether plaintiff is opposed to this motion. This request for enlargement is necessary because the parties have not been able to coordinate a draft of the joint status report. Government counsel was out of the office from December 1, 2006 through December 8, 2006. On December 11, 2006, Government counsel sent a draft joint status report to counsel for plaintiff, but counsel for plaintiff was in trial on December 11, 2006 and was unable to review and approve the draft in time for filing on December 11, 2006. For these reasons, we respectfully request that the Court grant an enlargement of three days, through and including December 14, 2006, within which the parties may file their joint status report.

Case 1:05-cv-00410-MMS

Document 29

Filed 12/11/2006

Page 2 of 2

Respectfully submitted, PETER D. KEISLER. Assistant Attorney General DAVID M. COHEN 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 December 11, 2006 Attorneys for Defendant