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

Case 1:04-cv-00557-GWM

Document 43

Filed 09/18/2006

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS ELLIS C. BLAND, et al., Plaintiffs, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) No. 04-557C ) ) (Judge George W. Miller) ) ) )

DEFENDANT'S MOTION FOR AN ENLARGEMENT OF TIME TO FILE JOINT STATUS REPORT Defendant, the United States, respectfully requests that the Court grant a two-day enlargement of time, from September 18, 2006, through and including September 20, 2006, for the parties to file a joint status report. This is our first request for an Undersigned counsel has

enlargement of time for this purpose.

been unable to reach opposing counsel to discuss this motion. Undersigned counsel provided opposing counsel with a draft status report on September 18, 2006. Opposing counsel suggested However,

a change to the status report, which has been made.

opposing counsel has not yet contacted undersigned counsel to provide final approval of the status report. A brief enlargement

of time is sought so that counsel for the parties can further consult regarding the status report.

Case 1:04-cv-00557-GWM

Document 43

Filed 09/18/2006

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CONCLUSION For the foregoing reasons, defendant, the United States, respectfully requests an enlargement of time until September 20, 2006, to file a joint status report. Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director s/Steven J. Gillingham STEVEN J. GILLINGHAM Assistant Director s/Richard P. Schroeder RICHARD P. SCHROEDER Trial Attorney Commercial Litigation Branch Civil Division U.S. Department of Justice Attn: Classification Unit Eighth Floor 1100 L Street, N.W. Washington, D.C. 20530 Tele: (202) 305-7562 Attorneys for Defendant September 18, 2006

Case 1:04-cv-00557-GWM

Document 43

Filed 09/18/2006

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CERTIFICATE OF FILING I hereby certify under penalty of perjury that on this day of September 18, 2006, "DEFENDANT'S MOTION FOR AN ENLARGEMENT OF TIME TO FILE JOINT STATUS REPORT," 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/Richard P. Schroeder