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

Case 1:04-cv-00461-BAF

Document 58

Filed 01/25/2007

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS CADDELL CONSTRUCTION CO., INC., ) ) Plaintiff, ) ) v. ) ) THE UNITED STATES, ) ) Defendant. )

No. 04-461C (Judge Bohdan A. Futey)

MOTION FOR EXTENSION OF TIME COMES NOW Plaintiff, Caddell Construction Co., Inc., and moves this Court for an extension of time to file the Stipulation of Facts pursuant to this Court's December 18, 2006 Order (Doc. 57). In support, the Plaintiff would show: 1. This Court's December 18, 2006 Order (Doc. 57) requires

that the Stipulation of Facts be submitted January 30, 2007. 2. Plaintiff respectfully requests that Plaintiff be granted

an extension of time so that the parties' Stipulation of Facts are due March 15, 2007. 3. This extension of time will not affect the upcoming trial

date of April 17, 2007. 4. Defendant has been advised of the filing of this Motion

and has stated that it does not oppose such Motion. WHEREFORE, Plaintiff respectfully submits that the be granted until March 15, 2007 to file the Stipulations of Fact.

F:\docs\HALLL\PLD\4460.035 Motion for Extension of Time re fact and law memo 02.wpd

Case 1:04-cv-00461-BAF

Document 58

Filed 01/25/2007

Page 2 of 2

Respectfully submitted, CADDELL CONSTRUCTION PLAINTIFF By: CO., INC.,

/s/ David W. Mockbee David W. Mockbee Mary Elizabeth Hall MOCKBEE HALL & DRAKE, P.A. Lamar Life Building, Ste 1000 317 E. Capitol Street Jackson, MS 39201 (601) 353-0035 - Telephone (601) 353-0045 - Facsimile ITS ATTORNEYS

CERTIFICATE OF SERVICE I, David W. Mockbee, do hereby certify that I have this day caused to be filed via the Official Electronic Document Filing System of the United States Court of Federal Claims ("CM/ECF") a true and correct copy of the above and foregoing Plaintiff's Motion for Extension of Time. Copies of this document will be transmitted via the Court's CM/ECF System to all counsel of record. Additional copies may be obtained through the Court's CM/ECF System. Dated: January 25, 2007. /s/ David W. Mockbee David W. Mockbee

2 F:\docs\HALLL\PLD\4460.035 Motion for Extension of Time re fact and law memo 02.wpd