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

Case 1:97-cv-00381-FMA

Document 212

Filed 03/26/2004

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS FRANCONIA ASSOCIATES, a Limited Partnership, et al., Plaintiffs, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) )

File No. 97-381C Judge Francis M. Allegra

PLAINTIFFS UNOPPOSED MOTION FOR ENLARGEMENT OF TIME Plaintiffs Franconia Associates, L.P., et al., hereby request, pursuant to Rule 6(b) of the Rules of the United States Court of Federal Claims, an extension of two weeks within which to file the joint stipulation referenced by the Court in its March 5, 2004 Order. The stipulation currently is due on April 2, 2004. By this motion, plaintiffs request that the deadline for filing the stipulation be extended up to and including April 16, 2004. This is plaintiffs first request for an enlargement of time for this purpose. Plaintiffs have informed counsel for the United States of their intention to seek this enlargement of time and the United States does not object to or intend to oppose plaintiffs motion. Counsel continue to work diligently in an effort to complete and file the stipulation ordered by the Court. However, significant commitments in other pending matters have hampered counsel s ability to complete the stipulation by the current deadline. For example, counsel for plaintiffs is involved in a complex, multi-party international trade secrets action titled BP Chemicals Limited vs. Yankuang Group Boyang Foreign Economic & Trade Co.,

Case 1:97-cv-00381-FMA

Document 212

Filed 03/26/2004

Page 2 of 3

Ltd., No. CV03-8167 (C.D. Cal.). That case is being handled on an expedited basis and currently is entrenched in discovery and motions practice. In addition, plaintiffs counsel are litigating several related cases, including Grass Valley Terrace v. United States, No. 98-726C (Fed. Cl.) (discovery pending); Adams, et al. v. United States, No. 96-699C (Fed. Cl.) (consolidated with Bellas Domas v. United States, No. 98-826C (Fed. Cl.)) (discovery pending); and Chancellor Manor, et al. v. United States, No. 02-5066 (Fed. Cir.) (discovery pending). Counsel also have a number of deadlines and commitments in other cases at this time, including PEC Solutions, Inc. v. NCS Pearson, Inc., No. 03-5214 (D. Minn.) (discovery pending); Nelson v. Tice, No. C2-01-0907 (Minn. Dist. Ct.) (discovery pending); Protest of Intercomp Company (agency bid protest); Protest of Digimarc ID Systems, LLC (state bid protest); Protest of General Security Services Corp. (GAO bid protest), as well as numerous administrative proceedings and non-litigation matters. Plaintiffs counsel of record also is scheduled to be out of the office until the week of April 5, 2004. For the reasons set forth above, plaintiffs respectfully request that the Court grant their Unopposed Motion for Enlargement of Time for good cause shown and extend the deadline for filing the stipulation referenced by the Court in its March 5, 2004 Order by fourteen days up to and including April 16, 2004.

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Case 1:97-cv-00381-FMA

Document 212

Filed 03/26/2004

Page 3 of 3

Dated: March 26, 2004 Filed Electronically

Respectfully submitted, s/ Jeff H. Eckland Mark J. Blando, Of Counsel FAEGRE & BENSON LLP 2200 Wells Fargo Center 90 South Seventh Street Minneapolis, Minnesota 55402-3901 Telephone: (612) 766-7000 Telecopy: (612) 766-1600

M2:20613259.01

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