Free Response to Motion - District Court of Federal Claims - federal

Case 1:94-cv-00366-JFM

Document 221

Filed 04/08/2005

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS CUMBERLAND CASUALTY & SURETY COMPANY, Plaintiff, v. ) ) ) ) ) ) ) ) ) ) )

No. 94-366C (Judge Merow)

THE UNITED STATES, Defendant.

DEFENDANT'S RESPONSE TO PLAINTIFF'S MOTION FOR EXTENSION OF TIME TO DISCOVERY DEADLINES SET FORTH IN FEBRUARY 9, 2995 ORDER Defendant, United States, in response to plaintiff's motion for an extension of the discovery deadlines, states that it has no objection to the granting of plaintiff's motion. Counsel for plaintiff in his motion states that his attempts to contact Government counsel regarding this motion were unavailing because he was unable to reach former Government counsel and was unaware of the identity of present Government counsel. This case was designated an electronic filing case on March 18, 2005. On March 30, 2005, undersigned counsel electronically filed her notice

Case 1:94-cv-00366-JFM

Document 221

Filed 04/08/2005

Page 2 of 2

of appearance Respectfully submitted, PETER D. KEISLER Assistant Attorney General s/ David M. Cohen DAVID M. COHEN Director s/ Leslie Cayer Ohta LESLIE CAYER OHTA Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L Street, N.W. Washington, DC 20530 (202) 616-0462 (202) 514-8624 (Fax) OF COUNSEL ELLEN M. EVANS Department of the Navy EFA Chesapeake, Suite 412 1314 Harwood St., SE Washington Navy Yard, 20374

April 8, 2005