Free Motion for Leave to File - District Court of Federal Claims - federal

Case 1:98-cv-00720-GWM

Document 173

Filed 09/16/2003

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 MOTION FOR LEAVE TO FILE EXHIBIT 1 TO PLAINTIFF'S RESPONSE TO DEFENDANT'S MOTION FOR SANCTIONS For the reasons set forth below, Precision Pine moves this Court for leave to file Exhibit 1 separately from the pleading to which it relates. As Precision Pine attempted to file its first electronic pleading, it became apparent that Exhibit 1 was a larger file than the Court allows. Precision Pine realized it would have to divide this Exhibit into two parts, a process that would take some time. In an effort to submit its Response to Defendant's Motion for Sanctions by the expedited 4:00 p.m. deadline set by this Court, Precision Pine proceeded to submit its Response and Exhibits 2-5. Counsel for Precision Pine then called the Clerk's Office at the Court of Federal Claims for instructions on how to proceed with submitting Exhibit 1, and was advised that filing the instant Motion for Leave would be the appropriate procedure.

For these reasons, plaintiff respectfully requests that this Motion for Leave to File Exhibit 1 to Plaintiff's Response to Defendant's Motion for Sanctions be granted, and that the Court include Exhibit 1 in its consideration of Plaintiff's Response. Exhibit 1 is attached hereto in two parts designated Exhibits 1A and 1B. 1

Case 1:98-cv-00720-GWM

Document 173

Filed 09/16/2003

Page 2 of 2

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 Attorneys for Plaintiff OF COUNSEL: Richard W. Goeken SALTMAN & STEVENS, P.C. 1801 K Street, N.W. Suite M-110 Washington, D.C. 20006 (202) 452-2150 Dated: September 16, 2003

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