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

Case 1:07-cv-00898-LAS

Document 14

Filed 08/13/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS GULF GROUP, INC., Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 07-898C (Sr. Judge Smith)

DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME Pursuant to Rule 6.1 of the Rules of the United States Court of Federal Claims ("RCFC"), defendant, the United States, respectfully requests a 43-day enlargement of time, to and including September 30, 2008, for the parties to submit a Joint Preliminary Status Report ("JPSR"). The JPSR currently is due on August 18, 2008. This is the fourth request for an enlargement of time for this purpose. Counsel for the parties have discussed this motion and its request for relief, and plaintiff's counsel has represented that plaintiff does not oppose this request. The requested enlargement is necessary to promote ongoing discussions between the parties concerning the possibility of resolving this dispute without further litigation. In addition, the requested 43-day extension will avoid the unnecessary expenditure of resources by the parties and the Court.

Case 1:07-cv-00898-LAS

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Filed 08/13/2008

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For the foregoing reasons, we respectfully request that the Court grant this unopposed motion for a 43-day enlargement of time, to and including September 30, 2008, for the parties to submit a Joint Preliminary Status Report. Respectfully submitted,

GREGORY G. KATSAS Assistant Attorney General

JEANNE E. DAVIDSON Director

s/Steven J. Gillingham STEVEN J. GILLINGHAM Assistant Director

s/Douglas G. Edelschick DOUGLAS G. EDELSCHICK Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L. Street, N.W. Washington, DC 20530 Tel: (202) 353-9303 August 13, 2008 Attorneys for Defendant

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Case 1:07-cv-00898-LAS

Document 14

Filed 08/13/2008

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CERTIFICATE OF SERVICE I hereby certify that on August 13, 2008, a copy of foregoing "DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT 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/Douglas G. Edelschick

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