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

Case 1:02-cv-01856-EGB

Document 16

Filed 09/11/2003

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS SCHOLTEN ROOFING SERVICES COMPANY, ) Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) No. 02-1856C ) )(Senior Judge Bruggink) ) )

DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Defendant, the United States, respectfully requests the Court to grant an enlargement of time of 14 days, to and including September 29, 2003, within which to file the parties' joint preliminary status report ("JPSR"). filed by September 15, 2003. The JPSR is due to be

This is our first request for an Counsel for plaintiff,

enlargement of time for this purpose.

Scholten Roofing Services Company ("Scholten"), has authorized us to state that Scholten does not oppose this motion. Counsel for the parties are cooperating in efforts to prepare and file the JPSR. They have conferred about the JPSR by

telephone, and they have worked independently to prepare draft JPSR. However, counsel for Scholten has been very busy, and the

parties have been unable to complete preparation of the JPSR. The full enlargement of time requested is needed. needed to complete the draft JPSR. Time is

In addition, time is needed

for review of the draft JPSR by agency counsel and by superiors within the Department of Justice.

Case 1:02-cv-01856-EGB

Document 16

Filed 09/11/2003

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For the reasons set forth above, we respectfully request that the Court grant our unopposed motion for an enlargement of time. Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director S/ Kathryn A. Bleecker KATHRYN A. BLEECKER Assistant Director S/ James W. Poirier JAMES W. POIRIER Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor, 1100 L St, N.W Washington, D.C. 20530 Tele: (202) 307-6289 Fax: (202) 514-7969 September 12, 2003 Attorneys for Defendant

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Case 1:02-cv-01856-EGB

Document 16

Filed 09/11/2003

Page 3 of 3

CERTIFICATE OF FILING I hereby certify that on September 12, 2003, a copy of the foregoing "DEFENDANT'S UNOPPOSED MOTION FOR AN 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. the Court's system. S/ James W. Poirier Parties may access this filing through