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

Case 1:01-cv-00056-ECH

Document 233

Filed 08/10/2007

Page 1 of 3

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 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 twenty two (22) days, until September 4, 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 on Monday, August 13, 2007. This is the defendant's first request for an extension of time for this purpose. On August 9, 2007, counsel for the defendant spoke with Mr. Kern, attorney for the plaintiffs, who stated that he did not oppose this motion. This motion is requested to allow the parties further time to determine whether the plaintiffs' application for attorneys' fees and costs can be resolved amicably and without further court involvement. Counsel for the parties have informally discussed the possibility of resolution of the two applications. An extension of time of twenty-two days would allow counsel to determine whether or not settlement of these matters may be feasible. Accordingly, the defendant respectfully requests that this Court grant it an extension of time of twenty-two (22) days in which to respond to the plaintiffs' bill of costs and application for attorneys fees.

Case 1:01-cv-00056-ECH

Document 233

Filed 08/10/2007

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 August 10, 2007 Attorneys for Defendant

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Case 1:01-cv-00056-ECH

Document 233

Filed 08/10/2007

Page 3 of 3

CERTIFICATE OF ELECTRONIC FILING I hereby certify that on August 10, 2007, a copy of the foregoing "Defendant's 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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