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

Case 1:08-cv-00006-RHH

Document 5

Filed 02/22/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS TRESLYN C. PATTERSON, Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 08-6C (Sr. Judge Hodges, Jr.)

DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Pursuant to Rules 6(b) and 6.1 of the Rules of the United States Court of Federal Claims ("RCFC"), defendant, the United States, respectfully requests a 30-day enlargement of time, to and including April 3, 2008, to file a response to the complaint. Our response is currently due on March 3, 2008. This is defendant's first request for an enlargement of time for this purpose. Defendant's counsel has spoken with plaintiff's counsel about this enlargement of time. Plaintiffs' counsel stated that plaintiff does not oppose this enlargement. The enlargement is requested because undersigned counsel of record for defendant requires additional time to confer and coordinate our response with the interested agency, the Department of Education. The enlargement is also requested because of counsel of record's current workload, which includes responding to a complaint in Oriska Insurance Company v. United States, Court of Federal Claims No. 2007-768, due February 29, 2008, drafting a reply brief in Scott A. Austen et. al v. United States, Court of Federal Claims No. 2007-589, due March 10, 2008, and drafting a motion for summary judgment in Lakeland Partners LLC v. United States, Court of Federal Claims No. 2006-295, due March 17, 2008. For the foregoing reasons, defendant respectfully requests that the Court grant its motion

Case 1:08-cv-00006-RHH

Document 5

Filed 02/22/2008

Page 2 of 3

for an enlargement of time of 30 days, to and including April 3, 2008, within which to file a response to the plaintiff's complaint. Respectfully submitted,

JEFFREY S. BUCHOLTZ Acting Assistant Attorney General

JEANNE E. DAVIDSON Director

/s/ Kirk T. Manhardt KIRK T. MANHARDT Assistant Director /s/ Carrie A. Dunsmore CARRIE A. DUNSMORE Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 1100 L Street, N.W., 8th Floor Washington, D.C. 20530 Tel: (202) 305-7576 Fax: (202) 514-8624 February 22, 2008 Attorneys for Defendant

Case 1:08-cv-00006-RHH

Document 5

Filed 02/22/2008

Page 3 of 3

Certificate of Filing I hereby certify that on this 22nd day of February, 2008, a copy of "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. Parties may access this filing through the Court's system. /s/Carrie A. Dunsmore Carrie A. Dunsmore