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

Case 1:04-cv-00461-BAF

Document 48

Filed 11/10/2006

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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 its Memorandum of Contentions of Fact and Law, exhibit and witness lists pursuant to this Court's July 31, 2006 Order (Doc. 47). Plaintiff would show: 1. This Court's July 31, 2006 Order (Doc. 47) requires that In support, the

Plaintiff's Memorandum of Contentions of Fact and Law, exhibit list, and witness list be submitted November 15, 2006, and

schedules the pre-trial conference for December 18, 2006. 2. one Plaintiff respectfully requests that Plaintiff be granted week so that Plaintiff's submissions are due

additional

November 22, 2006.

In that event, Defendant's submissions are due

December 7, 2006, or eleven days before the pre-trial conference. 3. This extension of time will not affect the pre-trial

conference scheduled for December 18, 2006 or the upcoming trial date to be decided at that pre-trial conference which this Court
F:\docs\HALLL\PLD\4460.035 Motion for Extension of Time re fact and law memo.wpd

Case 1:04-cv-00461-BAF

Document 48

Filed 11/10/2006

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previously indicated would be scheduled at the end of February or the first of March 2007 and is only one week beyond the

November 30, 2006 deadline for all filings in accordance with Appendix A per this Court's May 9, 2006 Order (Doc. 38). 4. Defendant has been advised of the filing of this Motion

and has stated that it does not oppose such Motion, assuming it is granted a similar extension of time. WHEREFORE, Plaintiff respectfully submits that it be granted one additional week to file its Memorandum of Contentions of Fact and Law, exhibit list, and witness list, and, if such is granted, then Defendant should be granted a similar extension. 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

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Case 1:04-cv-00461-BAF

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Filed 11/10/2006

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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: November 10, 2006. /s/ David W. Mockbee David W. Mockbee

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