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

Case 1:03-cv-01157-LJB

Document 60

Filed 08/14/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS A & D FIRE PROTECTION, INC., ) ) Plaintiff, ) ) ) v. ) ) THE UNITED STATES, ) ) Defendant. )

No. 03-1157 (Judge Bush)

DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME Pursuant to Rule 6(b)(1) and 6.1 of the United States Court of Federal Claims (RCFC), defendant United States respectfully requests a 4-day enlargement of time, to and including August 19, 2008, to file our mediation statement. Our response is currently due on August 15, 2007. This is defendant's first request for an enlargement for this purpose. On August 12, 2008, counsel for defendant communicated with William Bruckner, counsel for the plaintiffs, who indicated that he does not oppose this motion. The requested enlargement of time is necessary to allow respondent's counsel adequate time to prepare the Government's mediation statement. Defendant's counsel was responsible for filing a brief on July 25, 2008 in Texas National Bank v. United States, No. 07-355, and a brief in American Ordnance, LLC v. United States, No. 07-867 on July 29, 2008. Additionally, counsel is responsible for filing a brief in American Ordnance LLC v. United States, No. 08-238 on August 4, 2008. Counsel is also currently in trial and will be through August 15, 2008 in American Ordnance LLC v. United States, No. 07-867. Defendant's counsel is also responsible for filing a brief in the Court of International Trade on August 18, 2008 in Former Employees of Joy Technologies, Inc. v. Secretary of Labor, No. 06-00088.

Case 1:03-cv-01157-LJB

Document 60

Filed 08/14/2008

Page 2 of 3

For the foregoing reasons, defendant respectfully requests the Court to grant this motion for enlargement of time of four days, to and including, August 19, 2008, within which to file the Government's mediation statement. Respectfully submitted, GREGORY G. KATSAS Assistant Attorney General JEANNE E. DAVIDSON Acting Director

BRYANT G. SNEE Deputy Director

/s/ Joan M. Stentiford JOAN M. STENTIFORD Trial Attorney Commercial Litigation Branch Department of Justice Attn: Classification Unit 8th Floor 1100 L Street Washington, D.C. 20530 Tele: (202) 616-0341 Fax: (202) 514-8624 August 14, 2008 Attorneys for Defendant

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Case 1:03-cv-01157-LJB

Document 60

Filed 08/14/2008

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify under penalty of perjury that on this 14th day of August, 2008, the

foregoing "DEFENDANT'S 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. Parties may access this filing through the Court's system.

__/s/ Joan M. Stentiford JOAN M. STENTIFORD