Free Motion for Miscellaneous Relief - District Court of Federal Claims - federal

Case 1:98-cv-00720-GWM

Document 191

Filed 10/30/2003

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 (Chief Judge Damich)

PLAINTIFF'S UNOPPOSED MOTION FOR A TWO DAY ENLARGEMENT OF TIME TO FURTHER SUPPLEMENT ITS ANSWER TO INTERROGATORY NO. 34 For the reasons set forth below, plaintiff hereby moves the Court to grant it two additional days to further supplement its answer to defendant's Interrogatory No. 34. This is plaintiff's first request for an enlargement for this purpose. Plaintiff has conferred with counsel for defendant who has authorized plaintiff to inform the Court that defendant does not oppose the granting of two additional days, and that plaintiff has agreed with defendant to hand deliver its supplemental answer to Interrogatory No. 34 to defendant on or before 10: 00 A.M., Monday, November 3, 2003.

By Order dated October 23, 2003, the Court directed plaintiff to further supplement its answer to Interrogatory No. 34 by Thursday, October 30, 2003. Although plaintiff has largely completed its draft supplemental answer to this interrogatory, the President of Precision Pine has been unable to review the draft of this supplemental answer and confer with counsel regarding the same. Due to unforeseen problems with Precision Pine's Heber Sawmill, Precision Pine's President has been preoccupied with necessary hands-on management requirements. He has also 1

Case 1:98-cv-00720-GWM

Document 191

Filed 10/30/2003

Page 2 of 2

been required to travel extensively due to Arizona state joint house and senate forest health committee work which he has been appointed to perform. He will not be able to devote the time necessary to adequately review Precision Pine's draft of its supplemental answer and confer with counsel until the evening of Friday, October 31, at the earliest. Counsel for Precision Pine will then require additional time over the weekend to finalize this supplemental answer.

In light of these developments, the parties have conferred and plaintiff requests that the Court enter an order granting it two additional days, i.e., until on or before 10:00 a.m. on Monday, November 3, 2003 to serve its supplemental answer to Interrogatory No. 34 to defendant by hand-delivery. Defendant does not oppose the entry of such an order. 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: October 30, 2003

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