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

Case 1:96-cv-00408-LAS

Document 162

Filed 04/15/2008

Page 1 of 3

IN THE UNITED STATES COURT OF FEDERAL CLAIMS INNOVAIR AVIATION LIMITED, Plaintiff, v. UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 96-408C (Judge Smith)

DEFENDANT'S REQUEST FOR ENLARGEMENT OF TIME ON BEHALF OF BOTH PARTIES On behalf of both parties, defendant respectfully requests that the Court grant the parties one additional day, from April 15, 2008, until April 16, 2008, to file CD Rom copies of the parties' trial exhibits. The Government has contact plaintiff's counsel who has represented that plaintiff will join the Government in this request for additional time. Plaintiff's counsel and the Government's counsel have been working together to submit CD Rom copies of the parties' trial exhibits. Plaintiff supplied the Government with CD Rom copies of the parties exhibits in the late afternoon on April 14, 2008. The review process is timeconsuming because each exhibit must be checked page-by-page to determine whether the exhibit is complete, whether the pages are in the correct order, and whether the images of the pages are right-side-up or upside-down. After completing her review of plaintiff's exhibits, counsel for the Government has already determined that some of the exhibits on the CD Roms must be corrected prior to filing the CD Roms with the Court. We request this additional time so that we may be able to complete the process of reviewing and correcting all of the trial exhibits on the CD Roms prior to filing them with the Court.

Case 1:96-cv-00408-LAS

Document 162

Filed 04/15/2008

Page 2 of 3

For the foregoing reasons, we respectfully request that the Court grant our motion. Respectfully submitted,

JEFFREY S. BUCHOLTZ Acting Assistant Attorney General

/s/ Jeanne E. Davidson by Todd M. Hughes JEANNE E. DAVIDSON Director

/s/ Sheryl L. Floyd SHERYL L. FLOYD Senior Trial Counsel Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit, 8th Floor 1100 L Street, N.W. Washington, D.C. 20530 Tele: (202) 616-8278 Attorneys for Defendant APRIL 15, 2008

-2-

Case 1:96-cv-00408-LAS

Document 162

Filed 04/15/2008

Page 3 of 3

CERTIFICATE OF FILING I hereby certify that on this 15th day of APRIL, 2008, a copy of this "DEFENDANT'S REQUEST FOR ENLARGEMENT OF TIME ON BEHALF OF BOTH PARTIES" was filed e1ectronically. 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/ Sheryl L. Floyd