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

Case 1:98-cv-00720-GWM

Document 227

Filed 04/15/2004

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 UNOPPOSED 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 an one-day enlargement of time, to and including April 16, 2004, within which to file and serve its motion for summary judgment, proposed findings of uncontroverted fact, and accompanying appendix. The United States' motion for summary judgment, proposed findings of uncontroverted fact and appendix are currently due on April 15, 2004. This is the United States' first request for an enlargement of time for this purpose. We have discussed this request with Richard W. Goeken, counsel for plaintiff Precision Pine & Timber, Inc. ("Precision Pine"), who has informed us that Precision Pine consents to this motion. On March 19, 2004, the Court directed the parties to file dispositive motions on or before April 15, 2004. Work upon the United States' motion has proceeded diligently. The United States' motion for summary judgment on damages has been drafted and reviewed. A proposed statement of undisputed facts also has been prepared. This enlargement of time is sought to enable the United States' counsel of record to finish the voluminous accompanying appendix, incorporate accurate citations to appendix pages in the motion, and scan the appendix for electronic filing. The requested enlargement of time is reasonable under the circumstances.

Case 1:98-cv-00720-GWM

Document 227

Filed 04/15/2004

Page 2 of 2

For these reasons, the United States respectfully requests that the Court grant this unopposed motion for an enlargement of one day, to and including April 16, 2004, within which to file the United States' motion for summary judgment, statement of uncontroverted facts and appendix 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 Attorneys for Defendant April 15, 2004