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

Case 1:08-cv-00164-MCW

Document 15

Filed 08/29/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS JASMINE INTERNATIONAL TRADING AND SERVICES CO, W.L.L. Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) ) )

No. 08-164 (Judge Williams)

DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Pursuant to Rule 6(b) of the Rules of the United States Court of Federal Claims ("RCFC"), defendant requests an enlargement of time of 31 days, to and including September 29, 2008, within which to respond to plaintiff's complaint. response presently is due on August 29, 2008. Our

This is our fourth Plaintiff

request for an enlargement of time for this purpose.

has been contacted and does not oppose this request for an enlargement of time. In our July 22, 2008 motion for enlargement of time, we informed the Court that defendant had identified what it believes to be a jurisdictional defect in plaintiff's complaint. Defendant further informed the Court that defendant's counsel had consulted with plaintiff's counsel, and plaintiff's counsel had requested that defendant seek an enlargement of time so that plaintiff's counsel might have time to more closely examine the issue and consider the appropriate course of action. granted our motion on July 29, 2008. Plaintiff's counsel is currently considering the issue, and The Court

Case 1:08-cv-00164-MCW

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requires additional time to confer with her client about the appropriate next steps. Plaintiff has therefore requested that

the defendant seek this extension of the due date for filing its response to the complaint. For the foregoing reasons, defendant requests that the Court grant this motion for an enlargement of time. Respectfully submitted, GREGORY G. KATSAS Assistant Attorney General JEANNE E. DAVIDSON Director s/ Deborah A. Bynum DEBORAH A. BYNUM Assistant Director s/ Robert E. Chandler ROBERT E. CHANDLER Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit, 8th Floor 1100 L Street, N.W. Washington, D.C. 20530 Tel: (202) 514-4678 Fax: (202) 514-8624 August 29, 2008 Attorneys for Defendant

Case 1:08-cv-00164-MCW

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Filed 08/29/2008

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CERTIFICATE OF FILING

I hereby certify that on this 29th day of August 2008, a copy of the foregoing "DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT 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. filing through the Court's system. Parties may access this

s/ Robert E. Chandler