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

Case 1:04-cv-00473-MBH

Document 44

Filed 01/21/2005

Page 1 of 3

IN THE UNITED STATES COURT OF FEDERAL CLAIMS

M.G. CONSTRUCTION, INC., Plaintiff, v. THE UNITED STATES, Defendant.

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No. 04-00473 (Judge Horn)

DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME Pursuant to Rule 6.1 of the Rules of the Court of Federal Claims, defendant, the United States, respectfully requests that the Court enlarge by 7 days, from January 21, 2005, to and including January 28, 2005, the due date for the parties' filing of the Joint Stipulations of Uncontroverted Fact. This is the Government's first such request. Plaintiff's counsel has indicated that they support this request. The parties have almost completed the Joint Stipulation of Uncontroverted Facts with regard to Count I that this Court ordered us to file. However, we have not been able to agree upon the language of a completed version. The parties agree that we should be able to file the required Joint Stipulation of Uncontroverted Facts by January 28, 2005. Granting this enlargement of time should not cause any undue delay or prejudice. Accordingly, we respectfully request that the Court enlarge by 7 days, from January 21, 2005 to and including January 28, 2005, the due-date for parties' filing of the Joint Stipulation of Uncontroverted Facts.

Case 1:04-cv-00473-MBH

Document 44

Filed 01/21/2005

Page 2 of 3

Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director s/ James M. Kinsella JAMES M. KINSELLA Deputy Director s/ James D. Colt JAMES D. COLT Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L Street, NW Washington, D.C. 20530 Tel: (202) 514-7300 Fax: (202) 307-0972 January 21, 2005 Attorneys for Defendant

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Case 1:04-cv-00473-MBH

Document 44

Filed 01/21/2005

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that on this 21st day of January, 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 of record by operation of the Court's electronic filing system. Parties may access this filing through the Court's system.

s/ James D. Colt