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

Case 1:04-cv-00487-LB

Document 39

Filed 06/14/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS

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

THE UNITED STATES, Defendant.

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No. 04-487C (Judge Block)

DEFENDANT'S MOTION FOR EXTENSION OF TIME TO FILE JOINT STATUS REPORT Defendant, the United States, respectfully requests an extension of time of seven days, until June 21, 2007 for the parties to file the Joint Status Report directed by the Court's May 21, 2007 order. The joint status report is presently due on June 14, 2007. We request this extension of time because, despite both parties' efforts, we have been unable to discuss the report. This is because plaintiff's counsel, Mr. Hopkins, is away from his office and the attorney that he designated to act in his stead is away from this office today, as well. In the meantime, Government counsel has been away from the office for trial in West Palm Beach, Florida, for the case of SGS-92-X003 v. United States, (Fed. Cl. No. 97-579). Although the parties have attempted to discuss the matter, we have been unsuccessful. Accordingly, we respectfully request that the Court grant this seven day extension of time. Respectfully submitted, PETER D. KEISLER Assistant Attorney General

Case 1:04-cv-00487-LB

Document 39

Filed 06/14/2007

Page 2 of 2

JEANNE E. DAVIDSON Director

s/ Franklin E. White, Jr. FRANKLIN E. WHITE, JR Assistant Director s/ J. Reid Prouty / by s/ Claudia Burke J. REID PROUTY 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) 305-7586 Fax (202)514-7969 June 14, 2007 Attorneys for Defendant

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