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

Case 1:04-cv-00794-NBF

Document 11

Filed 09/10/2004

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS SPW ENGINEERING GROUP, INC., Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

04-794C (Judge Firestone)

DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME Pursuant to Rule 6(b) of the Rules of the Court of Federal Claims, defendant, the United States, respectfully requests the Court to enlarge the deadline for the parties' joint preliminary status report ("JPSR") by an additional 7 days, to and including September 17, 2004. The JPSR currently is due September 10, 2004. This is defendant's first motion for this purpose. Counsel for defendant has conferred with counsel for plaintiff, and is authorized to state that plaintiff does not oppose this motion. This motion is necessary due to the inability of the parties' counsel to complete their discussions regarding the JPSR because of unanticipated scheduling conflicts. As a result of these scheduling conflicts, the parties will not be able to complete the JPSR by the current deadline. The requested enlargement will allow counsel for the parties sufficient time to schedule the necessary conference and complete their discussions for the JPSR prior to its filing with the Court. Accordingly, the Government respectfully requests the Court to grant this unopposed motion to enlarge the deadline for the parties' JPSR by 7 days, to and including September 17, 2004.

Case 1:04-cv-00794-NBF

Document 11

Filed 09/10/2004

Page 2 of 3

Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director /s/ Robert E. Kirschman, Jr. ROBERT E. KIRSCHMAN, JR. Assistant Director /s/ Gregory T. Jaeger GREGORY T. JAEGER Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L Street, N.W. Washington, D.C. 20005 (202) 353-7955 September 10, 2004 Attorneys for Defendant

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Case 1:04-cv-00794-NBF

Document 11

Filed 09/10/2004

Page 3 of 3

CERTIFICATE OF FILING I hereby certify that on September 10, 2004, a copy of the foregoing DEFENDANT'S UNOPPOSED MOTION 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/ Gregory T. Jaeger