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

Case 1:08-cv-00022-ECH

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Filed 03/10/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS SUNSHINE DEVELOPMENT, INC., Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) No. 08-22C ) (Judge Hewitt) ) ) )

DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Defendant respectfully requests an enlargement of time of 35 calendar days, to and including April 15, 2008, within which to file its response to plaintiff's complaint in this case. Defendant's response currently is due to be filed on March 11, 2008. This is defendant's first request for an enlargement of Counsel for defendant has contacted

time for this purpose.

counsel for plaintiff regarding this motion, and he has stated that plaintiff does not oppose this motion. The additional time is necessary because counsel for defendant has not yet received the agency's comments regarding plaintiff's complaint. We rely upon agency counsel to prepare a

litigation report concerning the case, pursuant to 28 U.S.C. § 520, so that we may properly respond to actions filed against the United States. Counsel for defendant expects to receive the

agency's litigation report within the next few weeks. Additionally, undersigned counsel for defendant will be out of the office from March 17-21, 2008. Thus, the additional time is

necessary within which to review the litigation report, and

Case 1:08-cv-00022-ECH

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prepare and file our response to plaintiff's complaint. For the foregoing reason, we respectfully request that our unopposed motion for an enlargement of time be granted. Respectfully submitted, JEFFREY S. BUCHOLTZ Acting Assistant Attorney General JEANNE E. DAVIDSON Director s/ Martin F. Hockey, Jr. MARTIN F. HOCKEY, JR. Assistant Director s/ Lauren S. Moore OF COUNSEL: MICHAEL F. KIELY Attorney United States Postal Service Law Department LAUREN S. MOORE Attorney Commercial Litigation Branch Civil Division Department of Justice 1100 L Street, N.W. Attn: Classification Unit 8th Floor Washington, D.C. 20530 Tele: (202) 616-0333 Fax: (202) 514-8640 Attorneys for Defendant MARCH 10, 2008

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Case 1:08-cv-00022-ECH

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CERTIFICATE OF ELECTRONIC FILING I hereby certify that on the 10th day of MARCH, 2008, a copy of the foregoing "DEFENDANT'S UNOPPOSED 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. through the Court's system. /s/ Lauren S. Moore Parties may access this filing