Free Motion for Leave to Exceed Page Limit - District Court of Federal Claims - federal

Case 1:98-cv-00720-GWM

Document 379

Filed 08/25/2005

Page 1 of 2

IN THE UNITED STATES COURT OF FEDRAL CLAIMS PRECISION PINE & TIMBER, INC., Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

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

PLAINTIFF'S MOTION TO EXCEED PAGE LIMIT ON POST-TRIAL OPENNING BRIEF Plaintiff respectfully requests that the Court grant it leave to exceed the 60-page limit set for the opening post-trial brief. Counsel for plaintiff has contacted counsel for defendant, who has stated that defendant does not concur in this motion.

As the Court is aware, plaintiff bears the burden of proof of its damages. Needless to say, given all of the assertions that were raised in the course of a five and a half week trial, in meeting this burden there are many points that require exposition. As Plaintiff is nearing completion of its opening brief, despite its best efforts it keep its arguments short, it has realized that, in order to deal with the issues before the Court adequately, it requires that the page limitation be enlarged to 85.

For the foregoing reasons, plaintiff respectfully requests that the Court grant its motion to file an 85-page opening brief.

Case 1:98-cv-00720-GWM

Document 379

Filed 08/25/2005

Page 2 of 2

Respectfully submitted,

Alan I. Saltman SALTMAN & STEVENS, P.C. 1801 K Street, N.W. Suite M-110 Washington, D.C. 20006 (202) 452-2140 (202) 775-8217 ­ facsimile Counsel for Plaintiff OF COUNSEL: Richard W. Goeken Bryan T. Bunting SALTMAN & STEVENS, P.C. 1801 K Street, N.W. Suite M-110 Washington, D.C. 20006 (202) 452-2140 (202) 775-8217 ­facsimile Dated: August 24, 2005