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

Case 1:98-cv-00720-GWM

Document 186

Filed 10/21/2003

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)

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 a 1-day enlargement of time, to and including October 22, 2003, within which to file and serve more specific objections to the plaintiff's answer to interrogatory 34. The United States' response is currently due on October 21, 2003. This is the United States' first request for an enlargement of time for this purpose. We have discussed this request with counsel for plaintiff, Precision Pine & Timber, Inc. ("Precision Pine"), who has informed us that Precision Pine consents to this motion. This enlargement of time is sought to enable the United States' counsel of record to draft more detailed objections in accordance with the Court's October 20, 2003 order and to complete the supervisory review process. The Court's October 20, 2003 order was not received until after 6:00 p.m., which was after the undersigned counsel had left for the day. Additionally, on October 21, 2003, counsel was out of the office until approximately 1:00 p.m. arranging for the funeral and burial of his great aunt, who passed away late Saturday, October 18, 2003. As a result, counsel was unaware of the Court's order until shortly after 1:00 p.m. on October 21, 2003. Upon learning of the Court's order, counsel promptly contacted counsel for Precision Pine and drafted this motion. Thus, the requested enlargement of time is reasonable under the

Case 1:98-cv-00720-GWM

Document 186

Filed 10/21/2003

Page 2 of 2

circumstances and is necessary to ensure adequate time for defendant to prepare a thorough explanation of its objections to Precision Pine's interrogatory answer in accordance with the Court's October 20, 2003 order. For these reasons, the United States respectfully requests that the Court grant this motion for an enlargement of one day, to and including October 22, 2003, within which to file more detailed objections to Precision Pine's answer to interrogatory 34. 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 October 21, 2003