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

Case 1:05-cv-00183-NBF

Document 10

Filed 06/20/2005

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS KAEPER MACHINE, INC., Plaintiff, v. ) ) ) ) No. 05-183C ) ) (Judge Firestone) ) ) ) )

THE UNITED STATES, Defendant.

DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME Defendant respectfully requests an enlargement of time of three calendar days, to and including June 23, 2005, for the parties to file their Joint Preliminary Status Report ("JPSR"). The JPSR is presently due June 20, 2005. This is the first request for an enlargement of time to file the JPSR. Government counsel has discussed this motion with plaintiff's counsel and represents that plaintiff does not oppose it. The additional time is requested so that Government counsel may incorporate the input of plaintiff's counsel into the JPSR he has drafted and submit it for appropriate review prior to filing. The parties had discussed the general contents of the JPSR in the prior week, but Government counsel only received written inputs from plaintiff's counsel on June 20, 2005. Without an enlargement, this would not provide the Government sufficient time for its review process prior to filing the JPSR. For the foregoing reasons, defendant respectfully requests that the Court grant this unopposed motion for an enlargement of time. Respectfully Submitted, PETER D. KEISLER Assistant Attorney General

Case 1:05-cv-00183-NBF

Document 10

Filed 06/20/2005

Page 2 of 2

DAVID M. COHEN Director

s/James M. Kinsella JAMES M. KINSELLA Deputy Director

s/J. Reid Prouty J. REID PROUTY Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor, 1100 L Street, N.W. Washington, D.C. 20530 Tele: (202) 305-7586 Fax: (202) 514-7969 June 20, 2005 Attorneys for Defendant

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