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

Case 1:98-cv-00168-FMA

Document 318

Filed 12/07/2005

Page 1 of 3

IN THE UNITED STATES COURT OF FEDERAL CLAIMS ) ) ) Plaintiff, ) ) v. ) ) THE UNITED STATES, ) ) Defendant. ) __________________________________________) NORTH STAR ALASKA HOUSING CORPORATION,

No. 98-168C Judge Francis M. Allegra

CONSENT MOTION FOR AN ENLARGEMENT OF TIME WITHIN WHICH THE PARTIES MUST FILE POST-TRIAL BRIEFS Plaintiff North Star Alaska Housing Corporation respectfully requests an eleven-day enlargement of time within which the parties must file their post-trial briefs. The parties' briefs are currently due on December 12, 2005. The enlargement would bring the date for simultaneous filing of post-trial briefs to December 23, 2005. The Court has previously extended this due date from November 14, 2005 to November 21, 2005, and then from November 21, 2005 to December 12, 2005 to provide the parties an opportunity to focus their efforts on settlement of the case. Defendant United States of America has indicated its consent to this motion. The Court may enlarge the period within which to perform an act for good cause shown before the expiration of the original period. See Rule 6(b)(1) of the Rules of the United States Court of Federal Claims. Good cause for an enlargement exists because the parties have made substantial progress toward settlement of this case and require additional time within which to continue their negotiations. The requested enlargement of time through December 23, 2005 would allow the parties to further focus their efforts on settlement without the simultaneous burden of preparing post-trial briefs. Counsel for both parties remain cognizant of the need to

Case 1:98-cv-00168-FMA

Document 318

Filed 12/07/2005

Page 2 of 3

bring this case to a conclusion, and an enlargement until December 23, 2005 will provide the parties with sufficient time to either settle the case or turn their efforts to post-trial briefing. For these reasons, counsel for Plaintiff, with the consent of counsel for the Government, respectfully requests that the Court grant its motion of an enlargement of time of eleven days within which the parties must file post-trial briefs.

DATED: December 7, 2005

Respectfully submitted, s/ Paul W. Killian ________________________________ PAUL W. KILLIAN Akin Gump Strauss Hauer & Feld, L.L.P. 1333 New Hampshire Ave., N.W. Washington, D.C. 20036 (202) 887-4000 (phone) (202) 887-4288 (fax)

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Case 1:98-cv-00168-FMA

Document 318

Filed 12/07/2005

Page 3 of 3

CERTIFICATE OF FILING I hereby certify that a true and correct copy of the foregoing Consent Motion for an Enlargement of Time Within Which the Parties Must File Post-Trial Briefs was filed electronically on this 7th day of December 2005.

s/ Paul W. Killian ________________________ Paul W. Killian

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