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

Case 1:05-cv-00297-LSM

Document 9

Filed 08/11/2005

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS STERLING, WINCHESTER & LONG, L.L.C., Plaintiff, v. THE UNITED STATES OF AMERICA, Defendant. ) ) ) ) ) ) ) ) ) )

No. 05-297C (Judge Margolis)

JOINT REQUEST FOR ENLARGEMENT OF TIME The parties respectfully request an enlargement of time of 15 days, to and including September 2, 2005, to file their Joint Preliminary Status Report. The JPSR is currently due on August 18, 2005. This is the parties' first request for this purpose. Both parties join in this motion. The parties discussed the contents of the JPSR on July 21, 2005, and defendant's counsel provided a copy of a draft JPSR to plaintiff's counsel on that date. Plaintiff's counsel has recommended revisions to the Government's proposal, and the parties need additional time to finalize the JPSR. Defendant's counsel of record is scheduled to be out of the office from August 15 through August 26, 2005. Once she returns to the office, the parties anticipate that they will be able to make whatever modifications are necessary to the draft JPSR in order to file it with the Court by September 2, 2005. For the foregoing reasons, we respectfully request that the Court grant our motion for enlargement of time.

Case 1:05-cv-00297-LSM

Document 9

Filed 08/11/2005

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Respectfully submitted,

PETER D. KEISLER Assistant Attorney General

/s/ David M. Cohen DAVID M. COHEN Director

/s/ Frederick L. Wright FREDERICK L. WRIGHT Vaughn, Wright & Stearns LLP One Paces West ­ Suite 1740 2727 Paces Ferry Road, N.W. Atlanta, GA 30339 Tele: (770) 805-9889 Facsimile: (770) 805-9191 Attorney for Plaintiff DATE: 8/10/05

/s/ Sheryl L. Floyd SHERYL L. FLOYD Senior Trial Counsel Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L Street, N.W. Washington, D.C. 20530 Tele: (202) 307-0282 Facsimile: (202) 514-8624 OF COUNSEL: CHRISTOPHER BURTON United States Postal Service 475 L'Enfant Plaza, S.W. Washington, DC 20260 Attorneys for Defendant DATE: 8/11/05

Case 1:05-cv-00297-LSM

Document 9

Filed 08/11/2005

Page 3 of 3

CERTIFICATE OF FILING I hereby certify that on 11th day of AUGUST, 2005, a copy of the "JOINT REQUEST FOR ENLARGEMENT OF TIME" was filed electronically. I understand that notice of this filing will be sent to all parties by operation of the Court's electronic filing system. Parties may access this filing through the Court's system.

/s/ Sheryl L. Floyd