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

Case 1:02-cv-01795-JFM

Document 84

Filed 08/05/2005

Page 1 of 3

IN THE UNITED STATES COURT OF FEDERAL CLAIMS ____________________________________ ) THE SWEETWATER, A WILDERNESS ) LODGE LLC, ) ) Plaintiff, ) ) No. 02-1795C v. ) (Judge Merow) ) THE UNITED STATES, ) ) Defendant. ) ____________________________________) DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME We respectfully request an enlargement of time of two days, to and including August 12, 2005, within which to file and serve the pre-trial documents required by RCFC Appendix A, ¶¶ 14-16. Pursuant to the proposed pre-trial schedule adopted in the Court's March 29, 2005 order, our Appendix A filings are now due August 10, 2005. This is our first request for an enlargement of time. Plaintiff's counsel has stated that plaintiff does not oppose this request. The requested enlargement is necessary because on August 3, 2005, defendant's counsel was advised that by August 5, 2005, he must temporarily move all his files and his computer to a different office to permit repairs in the ceiling of his office that are planned to be performed on August 6, 2005. Packing files and related disruption has diverted time from counsel's pre-trial preparations in this case, and impeded his access to necessary documents. In these circumstances, we consider our request for a modest enlargement of time to be reasonable. For the foregoing reasons, we respectfully request that the Court grant our motion for an enlargement of time of two days, to and including August 12, 2005, to file the documents

Case 1:02-cv-01795-JFM

Document 84

Filed 08/05/2005

Page 2 of 3

required by RCFC Appendix A, ¶¶ 14-16.

Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director

s/ Kathryn A. Bleecker KATHRYN A. BLEECKER Assistant Director

s/ John H. Williamson JOHN H. WILLIAMSON Trial Attorney Commercial Litigation Branch Civil Division U.S. Department of Justice ATTN: Classification Unit 1100 L St. N.W., 8th floor Washington, D.C. 20530 Tel: (202) 307-0277 Fax: (202) 307-0972 August 5, 2005 Attorneys for Defendant

2

Case 1:02-cv-01795-JFM

Document 84

Filed 08/05/2005

Page 3 of 3

CERTIFICATE OF SERVICE I certify under penalty of perjury that on this 5th day of August, 2005, 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/ John H. Williamson