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

Case 1:04-cv-00487-LB

Document 19

Filed 03/08/2006

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.

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No. 04-487C (Judge Block)

JOINT REQUEST FOR ENLARGEMENT OF TIME Because counsel for the Government is participating in a meeting at the end of this week which will help determine the course of future settlement discussions, the parties respectfully request that the Court extend the deadlines set forth in its February 15, 2006 order by nine days. As directed by the Court, counsel for the parties began settlement discussions prior to March 1, 2006. These discussions have reached the point that additional consultations by Government counsel with administrators from the Aleutians East Borough (which would possibly be financially affected by any settlement) are necessary prior to determining the next appropriate step regarding settlement in this case. These administrators will be in Washington, DC at the end of this week and counsel for the Government has arranged a meeting with them to discuss matters relating to this case. Subsequent to this meeting, Government counsel expects to be able to make a more definitive determination, in consultation with plaintiff's counsel, of what steps, if any, would be most likely to lead to settlement of this case, including whether alternative dispute resolution would be appropriate at this point.

Case 1:04-cv-00487-LB

Document 19

Filed 03/08/2006

Page 2 of 2

Accordingly, the parties respectfully request that the Court extend the deadlines contained in its February 15, 2006 order by nine days. 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 JAMES M. KINSELLA Deputy Director

s/ J. Reid Prouty 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 Attorneys for Defendant March 8, 2006

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