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

Case 1:08-cv-00070-ECH

Document 5

Filed 03/26/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS INTERNATIONAL OUTSOURCING SERVICES, LLC, Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) )

No. 08-70C (Judge Hewitt)

DEFENDANT'S MOTION FOR ENLARGEMENT OF TIME Pursuant to Rule 6.1 of the Rules of the United States Court of Federal Claims, the United States respectfully requests a 14-day enlargement of time, from March 31, 2008, to and including April 14, 2008, within which to respond to plaintiff's complaint. This is defendant's first request for an enlargement of time for this purpose. Defendant's counsel has discussed this enlargement with David Hickey, counsel for plaintiff, who stated that plaintiff does not oppose this enlargement. In support of this motion, defendant states that, although it has received some documents from the agency, it has not received a litigation report. The agency has requested certain documents from storage that are required to respond to the complaint. As of the date of this motion, the agency is still waiting for those records, but hopes to receive those records within the next several days. At this point in time, defendant's counsel does not have enough information from the agency to complete defendant's response to the complaint. Accordingly, defendant respectfully requests that the Court grant defendant an enlargement of time to file a responsive pleading to April 14, 2008.

Case 1:08-cv-00070-ECH

Document 5

Filed 03/26/2008

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Respectfully submitted, JEFFREY S. BUCHOLTZ Acting Assistant Attorney General JEANNE E. DAVIDSON Director

s/ Mark A. Melnick MARK A. MELNICK Assistant Director

s/ Michael N. O'Connell MICHAEL N. O'CONNELL Trial Attorney Commercial Litigation Branch Civil Division U.S. Department of Justice 1100 L St., N.W., 8th floor Washington, D.C. 20530 Tel: (202) 353-1618 Fax: (202) 514-8624 March 26, 2008 Attorneys for Defendant

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Case 1:08-cv-00070-ECH

Document 5

Filed 03/26/2008

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CERTIFICATE OF SERVICE I certify under penalty of perjury that on this 26th day of March, 2008, a copy of the foregoing "DEFENDANT'S MOTION FOR ENLARGEMENT" 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/ Michael N. O'Connell

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