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

Case 1:04-cv-00471-EJD

Document 7

Filed 07/12/2004

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS JH PARKER CONSTRUCTION COMPANY, INC., Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) )

No. 04-471C (Chief Judge Damich)

DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Defendant, the United States, respectfully requests the Court to grant an enlargement of time of three days, to and including July 15, 2004, within which the parties may file their joint preliminary status report ("JPSR"). July 12, 2004. The JPSR is due on

This is our first request for an enlargement of Counsel for plaintiff,

time for this purpose.

J.H. Parker Construction Company, Inc. ("Parker") has authorized us to state that Parker does not oppose this motion. Counsel for the United States apologizes to the Court for the late filing of this motion. Until today, Monday, July 12,

2004, counsel anticipated making a timely filing of the JPSR. Most of the JPSR is completed. Only a small portion remains to

be drafted, and counsel anticipated that it could be drafted on July 12th (the day that agency counsel returns from vacation). However, an unexpected order received on Friday afternoon has created an immediate and inflexible deadline. Accordingly,

counsel did not learn until late Friday that he would be unable to timely file the JPSR in this case.

Case 1:04-cv-00471-EJD

Document 7

Filed 07/12/2004

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The full three days requested is needed.

Certain documents

must be reviewed by counsel for the United States, and certain consultations with agency counsel must also occur, before the draft JPSR can be completed. In addition, time for review by

counsel for the agency and by supervisors at the Department of Justice is needed. For these reasons, we respectfully request that our unopposed motion for an enlargement of time be granted. Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director S/Bryant G. Snee BRYANT G. SNEE Assistant Director S/ James W. Poirier JAMES W. POIRIER Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor, 1100 L St, N.W Washington, D.C. 20530 Tele: 202-307-6289 Fax: 202-514-7969 July 12, 2004 Attorneys for Defendant

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Case 1:04-cv-00471-EJD

Document 7

Filed 07/12/2004

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CERTIFICATE OF FILING I hereby certify that on July 12, 2004, a copy of the foregoing "DEFENDANT'S UNOPPOSED MOTION FOR AN 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. the Court's system. S/ James W. Poirier Parties may access this filing through