Free Motion for Extension of Time to File Response/Reply - District Court of Federal Claims - federal

Case 1:08-cv-00142-NBF

Document 18

Filed 08/13/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS SAUDI LOGISTICS AND TECHNICAL SUPPORT, Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) )

No. 08-142C (Judge Firestone)

DEFENDANT'S CONSENT MOTION FOR ENLARGEMENT OF TIME Pursuant to Rule 6(b)(1) of the Rules of the United States Court of Federal Claims ("RCFC"), defendant, the United States, respectfully requests a seven-day enlargement of time, to and including August 25, 2008, within which to file its response to plaintiff's motion to dismiss defendant's counterclaim for lack of jurisdiction. Our response is currently due on August 18, 2008. This is defendant's second request for an enlargement of time for this purpose. The undersigned has contacted plaintiff's counsel, who has stated that plaintiff consents to this motion. The additional time requested within which to file our response is necessary to allow counsel to draft the brief, to incorporate comments of agency counsel, and to obtain internal review of our brief. The undersigned was recently assigned as the lead attorney for the Government in Union Pacific Railroad Company v. United States Department of Homeland Security, No. 08-336 (D. NE). Counsel must draft a response to a motion for preliminary injunction in Union Pacific which is currently scheduled to be filed on August 15th. Additionally, counsel may have to attend oral argument in Omaha on August 18, 2008.

Case 1:08-cv-00142-NBF

Document 18

Filed 08/13/2008

Page 2 of 3

For the foregoing reasons, defendant respectfully requests that the Court grant this consent motion for an enlargement of time. Respectfully submitted, GREGORY G. KATSAS Assistant Attorney General JEANNE E. DAVIDSON Director /s/ Martin F. Hockey MARTIN F. HOCKEY Assistant Director /s/ David S. Silverbrand DAVID S. SILVERBRAND Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L Street Washington, D.C. 20530 tel: (202) 305-3278 fax: (202) 353-7988 August 13, 2008 Attorneys for Defendant

Case 1:08-cv-00142-NBF

Document 18

Filed 08/13/2008

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify under penalty of perjury that on this 13th day of August, 2008, a copy of the foregoing consent motion for an 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. Parties may access this filing through the Court's system.

s/ DAVID S. SILVERBRAND