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

Case 1:01-cv-00056-ECH

Document 237

Filed 09/04/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS JOHN W. BULL, et. al., Plaintiffs, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 01-56C (Judge Hewitt)

DEFENDANT'S SECOND UNOPPOSED MOTION FOR AN EXTENSION OF TIME Pursuant to Rule 6.1 of the Rules of the United States Court of Federal Claims, the defendant, the United States, respectfully submits this unopposed motion for an extension of time of 21 days, until September 25, 2007, in which to file a response to the plaintiffs' application for attorneys fees and bill of costs, filed on July 13, 2007. The defendant's responses are currently due September 4, 2007. This is the defendant's second request for an extension of time for this purpose, the Court having granted our request for an additional 22 days within which to file our response. Counsel for the plaintiffs stated that he did not oppose this motion. This motion is requested to allow the parties to continue discussions as to whether the plaintiffs' application for attorneys fees and costs can be resolved amicably and without further Court involvement. Counsel for the parties have had several discussions regarding the possibility of resolution of the two applications. An extension of time of 21 days would allow counsel to continue these discussions. Accordingly, the defendant respectfully requests that this Court grant it an extension of time of 21 days in which to respond to the plaintiffs' bill of costs and application for attorneys fees.

Case 1:01-cv-00056-ECH

Document 237

Filed 09/04/2007

Page 2 of 3

Respectfully Submitted, PETER D. KEISLER Assistant Attorney General JEANNE E. DAVIDSON Director S/Kathryn A. Bleecker KATHRYN A. BLEECKER Assistant Director

S/Tara K. Hogan TARA K. HOGAN Trial Attorney Commercial Litigation Branch Civil Division U.S. Department of Justice 1100 L Street, N.W., attn: 8th floor Washington, D.C. 20530 Tele: (202) 616-2228 Fax: (202) 305-7643 September 4, 2007 Attorneys for Defendant

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Case 1:01-cv-00056-ECH

Document 237

Filed 09/04/2007

Page 3 of 3

CERTIFICATE OF ELECTRONIC FILING I hereby certify that on September 4, 2007, a copy of the foregoing "Defendant's Second Unopposed Motion for an Extension of Time" was filed electronically. I understand that notice of this filing will be sent to all parties by operation of the Court's electronic filing system. Parties may access this filing through the Court's system.

s/ Tara K. Hogan

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