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

Case 1:04-cv-00487-LB

Document 9

Filed 08/30/2004

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS

TRAVELERS CASUALTY AND SURETY COMPANY OF AMERICA, a Connecticut corporation Plaintiff, v.

THE UNITED STATES, Defendant.

) ) ) ) ) ) ) ) ) ) ) )

No. 04-487C (Judge Block)

JOINT MOTION FOR AN ENLARGEMENT OF TIME Pursuant to Rule 6(b) of the Rules of this Court, both parties respectfully request a 15-day enlargement of time to and including September 17, 2004, within which to file our joint preliminary status report. According to the docket sheet, the report is currently due on September 2, 2004. This is the parties' first request for an enlargement of time for this purpose. This request is necessary for two reasons. First, with the exception of two days, Government counsel was out of the office from July 14, 2004 until August 30, 2004, due to paternity leave. Upon Government counsel's return to the office, plaintiff's counsel is actively involved in a mediation in the matter of Travelers Casualty and Surety Company of America v. Phillip E. Godfrey, et al., No. CV4-0662P (United States District Court for the Western District of Washington). In that matter, counsel for Travelers must submit a mediation brief on September 3, 2004, and participate in a mediation on September 7, 2004 ­ both of which will occupy his time during the first week of September.

Case 1:04-cv-00487-LB

Document 9

Filed 08/30/2004

Page 2 of 2

For these reasons, the parties respectfully requests that the Court grant our unopposed motion for an enlargement of time of 15 days, to and including September 17, 2004, within which to respond to plaintiff's complaint. Respectfully submitted, s/ James T. Hopkins JAMES T. HOPKINS Schiffrin Olson Schlemlein & Hopkins 1601 Fifth Avenue, Suite 2500 Seattle, WA 98101 Washington, DC 20005 Tel. (206) 448-8100 Fax (206) 448-8514 Attorneys for Plaintiff PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director

s/ James M. Kinsella by Franklin E. White, Jr. JAMES M. KINSELLA Deputy Director

s/ David R. Feniger DAVID R. FENIGER Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L Street, N.W. Washington, D.C. 20005 Tel. (202) 307-3390 Fax (202) 305-2118 Attorneys for Defendant August 30, 2004

2