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

Case 1:98-cv-00720-GWM

Document 445

Filed 11/08/2007

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS

PRECISION PINE & TIMBER, INC., Plaintiff, v. THE UNITED STATES, Defendant.

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No. 98-720 C (Judge George W. Miller)

PLAINTIFF'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME WITHIN WHICH TO COMPLETE RECALCULATION OF DAMAGES For the reasons set forth below, plaintiff hereby moves for an enlargement of seventeen (17) days, to and including November 30, 2007, within which to complete its recalculation of damages in accordance with the Court's decision of September 14, 2007 (the current deadline for which is November 13, 2007). Plaintiff's counsel has communicated with counsel for the defendant who has advised that he has no objection to this motion.

Counsel of record for Precision Pine & Timber, Inc. has been involved in the preparation of a petition for a writ of certiorari in the Supreme Court of the United States, and as a result has been unable to devote sufficient time to preparing the recalculation.

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Case 1:98-cv-00720-GWM

Document 445

Filed 11/08/2007

Page 2 of 2

For this reason, Precision Pine & Timber, Inc. respectfully requests that the Court enter an order granting plaintiff a 17-day enlargement to November 30, 2007, within which to prepare its recalculation of damages.

Respectfully submitted,

s/Alan I. Saltman SALTMAN & STEVENS, P.C. 1801 K Street, N.W. Suite M-110 Washington, D.C. 20006 (202) 452-2140 Counsel for Plaintiff OF COUNSEL: Richard W. Goeken SALTMAN & STEVENS, P.C. 1801 K Street, N.W. Suite M-110 Washington, D.C. 20006 (202) 452-2140 Dated: November 8, 2007

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