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

Case 1:02-cv-00713-EJD

Document 26

Filed 07/28/2003

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS JCI INTERNATIONAL, INC. , Plaintiff, v. UNITED STATES Defendants. --------------------------------------------------UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME (Filed electronically) Plaintiff JCI INTERNATIONAL, INC. respectfully requests the Court to grant an enlargement of time of 50 days, to and including September 19, 2003, within which to file the parties' joint preliminary status report ("JPSR"). Counsel for defendant, THE UNITED STATES has authorized us to state that the United States does not oppose this motion. Plaintiff JCI has submitted a settlement proposal which is under review by the Department of Justice as attorney for Defendant. We respectfully request this stay of proceedings as the undersigned attorney for Plaintiff is recovering from unexpected by-pass surgery which took place on July 10, 2003 and has been directed by his physicians not to return to practice for an expected period of eight weeks. For the reasons set forth above, we respectfully request that the Court grant our CASE NO. 02-713-C

Case 1:02-cv-00713-EJD

Document 26

Filed 07/28/2003

Page 2 of 2

unopposed motion for an enlargement of time. Respectfully submitted, KINBERG & BICKFORD, LLC By:s/ Edward J. Kinberg Edward J. Kinberg 2101 S. Waverly Place Ste. 200E Melbourne, FL 32901 (321) 722-2006 (321) 722-3352

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