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

Case 1:98-cv-00720-GWM

Document 374

Filed 07/26/2005

Page 1 of 2

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

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

DEFENDANT'S MOTION FOR ENLARGEMENT OF TIME Pursuant to Rule 6(b)(1) of the Rules of the United States Court of Federal Claims ("RCFC"), defendant, the United States, respectfully requests a seven-day enlargement of time, to and including Tuesday, August 2, 2005, within which to file and serve corrections to the trial transcript. The parties' transcript corrections are currently due Tuesday, July 26, 2005. This is the United States' first request for an enlargement of time for this purpose. We have sought to discuss this motion with Alan I. Saltman, counsel for plaintiff, Precision Pine & Timber, Inc. ("Precision Pine"), who has not currently responded to our inquiries. On Friday, July 22, 2005, Precision Pine provided to undersigned counsel a 30-page table containing proposed corrections to the trial transcript. Upon receiving Precision Pine's proposed corrections, we wrote to Precision Pine proposing that the parties jointly submit mutually agreed transcript corrections to the Court. See Letter from David A. Harrington to Alan I. Saltman (July 25, 2005) (attached as Exhibit A). At the same time, we informed Precision Pine that it would not be feasible to review their proposed corrections, cross-reference their list of corrections and the list that the United States was preparing, and prepare a consolidated list by July 26, 2005. Id. As a result, we proposed that the parties seek a one week enlargement to

Case 1:98-cv-00720-GWM

Document 374

Filed 07/26/2005

Page 2 of 2

enable, to greatest extent possible, the filing of a single, consolidated list of mutually agreed upon corrections to the trial transcript. Id. Accordingly, the United States respectfully requests that the Court grant this motion for an enlargement of time of seven days to enable to parties to file a consolidated list of corrections to the trial transcript in this action. Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director s/ Kathryn A. Bleecker KATHRYN A. BLEECKER Assistant Director s/ David A. Harrington DAVID A. HARRINGTON Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L Street, N.W. Washington, D.C. 20530 (202) 307-0277 July 26, 2005 Attorneys for Defendant