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

Case 1:08-cv-00191-FMA

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Filed 05/12/2008

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UNITED STATES COURT OF FEDERAL CLAIMS CHENEGA TECH. SERV. CORP., Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

Case No. 08-191C (Judge Allegra)

DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Defendant respectfully requests an enlargement of time of 45 days, to and including July 3, 2008, within which to respond to plaintiff's complaint. Defendant's answer is currently due on May 19, 2008. This is our first request for an enlargement of time for this purpose. Plaintiff's counsel has indicated that plaintiff does not oppose this motion. Counsel is currently working on several matters, which have required counsel's attention and make this request for an extension necessary. These matters include (1) EOD Tech. v. United States, No. 08-283C (Fed. Cl.), a bid protest proceeding before the Court of Federal Claims; (2) City Line Joint Venture v. United States, No. 96-738 (Fed. Cl.), in which the Government's reply brief is due on May 23, 2008; (3) Brickwood Contractors, Inc. v. United States, No. 06-695 (Fed. Cl.), in which the Government's response to a Rule 60(b) motion is due on May 16, 2008; (4) Engler v. Department of the Navy, No. 2008-3175 (Fed. Cir.), in which the Government's informal brief is due on May 27, 2008; (5) Foster v. Department of Defense, No. 2007-3264 (Fed. Cir.), in which the Federal Circuit has scheduled oral argument for June 4, 2008; and (6) IBA Molecular North America, Inc. v. United States, No. 08-263C (Fed. Cl.), in which the Government's answer is due on June 9, 2008. For the foregoing reasons, we respectfully request the Court to grant our motion for an

Case 1:08-cv-00191-FMA

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Filed 05/12/2008

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enlargement of time of 45 days.

Respectfully submitted,

JEFFREY S. BUCHOLTZ Acting Assistant Attorney General

JEANNE E. DAVIDSON Director

s/Reginald Blades REGINALD BLADES Assistant Director

s/Sean M. Dunn SEAN DUNN Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 1100 L Street, N.W., 8th Floor Washington, D.C. 20530 Tele: (202) 616-0883 Fax: (202) 353-7988

Attorneys for Defendant May 12, 2008

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Case 1:08-cv-00191-FMA

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Filed 05/12/2008

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CERTIFICATE OF FILING I hereby certify that on this 12th day of May 2008, a copy of the foregoing "Defendant's Unopposed For An Enlargment 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/Sean M. Dunn