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

Case 1:05-cv-00217-LAS

Document 42

Filed 01/08/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS ARBITRAJE CASA DE CAMBIO, S.A. de C.V. et al., Plaintiffs, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) )

No. 05-217C (Senior Judge Smith)

PLAINTIFFS' UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME IN WHICH TO FILE THE JOINT PRELIMINARY STATUS REPORT AND FOR RESCHEDULING OF THE TELEPHONIC STATUS CONFERENCE Pursuant to Rules 6(b)(1) and 6.1 of the Rules of the United States Court of Federal Claims, Plaintiffs Arbitraje Casa de Cambio S.A. de C.V. respectfully request that this Court (1) grant an enlargement of 30 days to and including February 15, 2008 to allow the parties to prepare and submit the Joint Preliminary Status Report ("JPSR") and (2) reschedule the telephonic status conference, currently scheduled for January 24, 2008, to February 28, 2008. In support of this motion, Plaintiffs state as follows: An enlargement of time to file the JPSR and a rescheduling of the telephonic status conference is necessary because undersigned counsel has had difficulty contacting representatives of the Plaintiffs, all of whom reside in Mexico. Plaintiffs' counsel needs additional time to consult with the Plaintiffs before he will be able to meaningfully participate in the crafting and filing of the JPSR. Because the Court's telephonic status conference currently scheduled for January 24, 2008 will likely concern issues raised in the JPSR, Plaintiffs also respectfully request that the Court postpone that conference until February 28, 2008. Counsel for Defendant has stated that Defendant does not oppose this motion.

Case 1:05-cv-00217-LAS

Document 42

Filed 01/08/2008

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Respectfully submitted,

s/ Howard G. Slavit Howard G. Slavit DC Bar No. 962886 SAUL EWING LLP 2600 Virginia Avenue, N.W. Suite 1000 ­ The Watergate Washington, DC 20037-1922 (202) 333-8800 (tel.) (202) 337-6065 (fax) Mark C. Cawley DC Bar No. 468611 SAUL EWING LLP 3800 Centre Square West 1500 Market St. Philadelphia, PA 19102 (215) 972-1887 (tel.) (215) 972-2298 (fax) Counsel for the Plaintiffs

Dated: January 8, 2008

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Case 1:05-cv-00217-LAS

Document 42

Filed 01/08/2008

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CERTIFICATE OF FILING I hereby certify that on January 8, 2008, a copy of the foregoing "Plaintiffs' Unopposed Motion for an Enlargement of Time in Which to File The Joint Preliminary Status Report and for Rescheduling of the Telephonic Status Conference" 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/ Howard G. Slavit

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