Case 1:05-cv-00170-LAS 1:05-cv-00179-ECH
Document 18 Document 15
Filed 08/17/2005 10/19/2005
Page 1 of 2
IN THE UNITED STATES COURT OF FEDERAL CLAIMS
SWANSON GROUP, INC., Plaintiff, v. THE UNITED STATES, Defendant.
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No. 05-179C (Judge Hewitt)
JOINT MOTION FOR AN ENLARGEMENT OF TIME TO FILE JOINT PRELIMINARY STATUS REPORT Pursuant to Rule 6(b)(1) of the Rules of the United States Court of Federal Claims ("RCFC"), defendant, the United States, and plaintiff, Swanson Group, Incorporated ("Swanson") respectfully request a 30-day enlargement of time, to and including September 19, 2005, within which to file their joint preliminary status report ("JPSR"). Our JPSR is currently due on August 18, 2005. This is the parties' first request for an enlargement of time for this purpose. The enlargement is requested because the parties need additional time to consult with client representatives and agency counsel, to further discuss the best way to proceed in this case, and to attempt to reach consensus on various issues, including the relevant factual and legal issues in the case and a discovery plan. The parties believe they can accomplish this within the next thirty days. For the foregoing reasons, the parties jointly request that the Court grant this motion for a 30-day enlargement of time within which to file their JPSR.
Case 1:05-cv-00170-LAS 1:05-cv-00179-ECH
Document 18 Document 15
Filed 08/17/2005 10/19/2005
Page 2 of 2
Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director s/ Kathryn A. Bleecker KATHRYN A. BLEECKER Assistant Director OF COUNSEL: MARCUS WAH Associate Regional Attorney USDA-OGC, Pacific Region 1734 Federal Building 1220 S.W. Third Ave Portland, OR 97204-2825
s/ Lindsay Williams LINDSAY WILLIAMS Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Phone: (202) 353-7995 Fax: (202) 514-8624 Attorneys for Defendant s/Gary G. Stevens GARY G. STEVENS Saltman & Stevens P.C. 1801 K Street, NW Suite M110 Washington, D.C. 20006 Ph: (202) 452-2140 Fax: (202) 775-8217
August 18, 2005
August 18, 2005
Attorney for Plaintiff