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

Case 1:01-cv-00316-FMA

Document 51

Filed 06/30/2005

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS __________________________________________ ) ) ) Plaintiff, ) ) v. ) ) THE UNITED STATES, ) ) Defendant. ) __________________________________________) SWARTZ ASSOCIATES, INC.,

No. 01-316C (Judge Allegra)

JOINT REQUEST FOR AN ENLARGEMENT OF TIME TO FILE A JOINT STATUS REPORT ISSUED PURSUANT TO THE COURT'S ORDER DATED JUNE 6, 2005 Plaintiff, Swartz Associates, Inc., ("Swartz") and defendant, the United States, hereby request an enlargement of time to file a joint status report pursuant to the Court's Order dated June 6, 2005. The current status of this case is that Swartz has submitted contract claims to the contracting officer of the United States Marshals Service and those claims have been denied. The parties wish to discuss the possibility of settlement, or failing that, a mutually acceptable schedule for proceeding with the case. In order to facilitate these discussions, the parties request a 31-day enlargement of time to file the joint status report. The current date for filing the joint status report is June 30, 2005. Therefore, the parties request an enlargement of time until Monday, August 1, 2005, to file a joint status report.

Case 1:01-cv-00316-FMA

Document 51

Filed 06/30/2005

Page 2 of 3

Respectfully submitted,

/s/ Gregg Sodini GREGG SODINI, ESQ. Sodini & Spina 510 Thornall Street Suite 180 Edison, New Jersey 08837 Attorneys for plaintiff

PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director /s/ James M. Kinsella JAMES M. KINSELLA Deputy Director /s/ John H. Roberson JOHN H. ROBERSON Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L Street, N.W. Washington, D.C. 20530 Tel: (202) 353-7972 Attorneys for Defendant

Dated: June 30, 2005

Of Counsel: JONI GIBSON Associate General Counsel United States Marshals Service 600 Army-Navy Drive Suite 1250 Arlington, VA 22202 Tel: (202) 307-9054

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Case 1:01-cv-00316-FMA

Document 51

Filed 06/30/2005

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that on this 30th day of June 2005, I caused to be placed in the United States mail (first class, postage prepaid) and to be served by facsimile, a copy of "JOINT REQUEST FOR AN ENLARGEMENT OF TIME TO FILE A JOINT STATUS REPORT ISSUED PURSUANT TO THE COURT'S ORDER DATED JUNE 6, 2005" addressed as follows:

GREGG SODINI, ESQ. Sodini & Spina 510 Thornall Street Suite 180 Edison, New Jersey 08837 Facsimile (732) 603-0441 I also hereby certify that on this 30th day of June 2005, a copy of the foregoing "JOINT REQUEST FOR AN ENLARGEMENT OF TIME TO FILE A JOINT STATUS REPORT ISSUED PURSUANT TO THE COURT'S ORDER DATED JUNE 6, 2005" 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/ John H. Roberson John H. Roberson

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