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

Case 1:01-cv-00351-JFM

Document 70

Filed 05/25/2006

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS CLEARWATER CONSTRUCTORS, INC., ) ) Plaintiff, ) ) v. ) ) THE UNITED STATES, ) ) Defendant. )

No. 01-351C (Judge Merow)

DEFENDANT'S MOTION FOR ENLARGEMENT OF TIME Defendant respectfully requests an enlargement of time of seven calendar days, to and including June 1, 2006, for the parties to file the joint status report required by the Court's April 28, 2006 order. The joint status report is presently due May 25, 2006. This is defendant's first request for an enlargement of time for this matter. We request this enlargement because we have been unable to communicate with plaintiff's counsel regarding the final contents of the joint status report. We had earlier discussed proposed scheduling with plaintiff's counsel and came to general agreement, but a few issues relating to particular dates were not resolved prior to plaintiff's counsel's departure for travel away from his office. The parties had hoped to be able to communicate via e-mail to resolve these matters, but have not been successful. Nevertheless, the differences between the parties are minor and we anticipate their quick resolution once communication between counsel is re-established. For the foregoing reasons, defendant respectfully requests that the Court grant this motion for an enlargement of time. Respectfully submitted,

Case 1:01-cv-00351-JFM

Document 70

Filed 05/25/2006

Page 2 of 2

PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director

s/ Todd M. Hughes TODD M. HUGHES Assistant Director

s/ J. Reid Prouty J. REID PROUTY Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor, 1100 L Street, NW Washington, D.C. 20530 Tel: (202) 305-7586 Fax: (202) 514-7969 May 25, 2006 Attorneys for Defendant