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

Case 1:99-cv-00961-LAS

Document 127

Filed 05/27/2008

Page 1 of 3

IN THE UNITED STATES COURT OF FEDERAL CLAIMS WHITE BUFFALO CONSTRUCTION, INC., Plaintiff, v. ) ) ) ) ) ) ) ) ) ) )

No. 99-961C (Consolidated with Nos. 00-415C and 07-738C) (Senior Judge Smith)

THE UNITED STATES, Defendant.

DEFENDANT'S CONSENT MOTION FOR AN ENLARGEMENT OF TIME WITHIN WHICH THE PARTIES MAY CONDUCT APPENDIX A, PARAGRAPH 13(a)-(c) PRETRIAL ACTIVITIES, AND REQUEST FOR EXPEDITED CONSIDERATION Defendant, the United States, respectfully requests that the Court grant an enlargement of time of nine days, to and including Thursday, June 5, 2008, within which the parties may conduct the pretrial activities (including the meeting of counsel and the exchange of witness and exhibit lists) set forth in Appendix A, Paragraph 13(a)-(c) to the Rules of the United States Court of Federal Claims. The parties are currently due to conduct those

activities by today, May 27, 2008. This is defendant's first request for an enlargement of time for this purpose. We request the enlargement because the

parties, today, have agreed that they wish to conduct those activities face-to-face in Portland, Oregon, on June 5, 2008, after the oral argument that the Court has scheduled to take place there on that date. Counsel for plaintiff has represented to counsel for defendant that plaintiff consents to this request. For the

Case 1:99-cv-00961-LAS

Document 127

Filed 05/27/2008

Page 2 of 3

foregoing reasons, the United States respectfully requests that the Court grant this consent motion for an enlargement of time of nine days, to and including Thursday, June 5, 2008, within which the parties may conduct Appendix A, Paragraph 13 pretrial activities. Because those activities are due today, we

respectfully request expedited consideration of this motion. Respectfully submitted, GREGORY G. KATSAS Acting Assistant Attorney General JEANNE E. DAVIDSON Director

s/Todd M. Hughes TODD M. HUGHES Deputy Director

s/Timothy P. McIlmail TIMOTHY P. MCILMAIL Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L Street, N.W. Washington, D.C. 20530 Telephone: (202) 616-0342 Facsimile: (202) 514-7965 May 27, 2008 Attorneys for Defendant

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Case 1:99-cv-00961-LAS

Document 127

Filed 05/27/2008

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that on May 27, 2008, a copy of the foregoing Defendant's Consent Motion For An Enlargement Of Time Within Which The Parties May Conduct Appendix A, Paragraph 13 Pretrial Activities, And Request For Expedited Consideration 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. Parties may access this filing through

s/Timothy P. McIlmail