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

Case 1:98-cv-00720-GWM

Document 287

Filed 03/02/2005

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)

JOINT MOTION FOR AN ENLARGEMENT OF TIME TO FILE JOINT STIPULATIONS OF FACT Pursuant to the Court's January 4, 2005 order, the parties are to file Joint Stipulations of Fact on March 2, 2005. Toward this end, the parties have exchanged draft stipulations and, on February 28, 2005, the parties met and discussed those draft stipulations for several hours. That meeting was productive and, at this time, the parties believe that several areas exist where stipulations can be agreed upon that will help to streamline and better focus the issues for trial. However, over the past several days the parties have also been in engaged in an out-of-town deposition of plaintiff's expert witness and the exchange and review of preliminary exhibits. As a result, the precise language of the stipulations remains to be finalized. Accordingly, the parties respectfully request that (1) the Court grant the parties an additional 9 days, to and including Friday, March 11, 2005, within which to file their stipulations, and (2) that the parties be permitted to supplement that initial filing with such additional stipulations as they may be able to agree upon thereafter. Respectfully submitted, PETER D. KEISLER Assistant Attorney General

Case 1:98-cv-00720-GWM

Document 287

Filed 03/02/2005

Page 2 of 2

DAVID M. COHEN Director s/ Kathryn A. Bleeker KATHRYN A. BLEECKER Assistant Director s/ Alan I. Saltman Alan I. Saltman SALTMAN & STEVENS, P.C. 1801 K Street, N.W. M-110 Washington, D.C. 20006 (202) 452-2140 (202) 775-8217 (fax) s/ David A. Harrington DAVID A. HARRINGTON Trial Attorney Commercial Litigation Branch Civil Division U.S. Department of Justice Attn: Classification Unit 8th Floor 1100 L Street, N.W. Washington, D.C. 20530 (202) 307-0277 (202) 307-0972 (fax) Attorneys for Defendant

Attorney for Plaintiff March 2, 2005

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