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

Case 1:07-cv-00873-MMS

Document 9

Filed 03/06/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS

PARADIGM LEARNING, INC., Plaintiff, v. THE UNITED STATES, Defendant.

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No. 07-873C (Judge Sweeney)

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 12-day enlargement of time, to and including March 24, 2008, within which to file a response to the complaint filed by plaintiff, Paradigm Learning, Inc. ("Paradigm"). Our first enlargement in this case was for 30 days. Our response is currently due on March 12, 2008. Plaintiff's counsel does not oppose our request. Undersigned counsel currently has reply briefs due on March 12, 2008, in the following cases before this Court: Smalls v. United States, No. 07-715C, and Olin v. United States, No. 07728C. The additional time requested is necessary, therefore, for defendant's counsel to prepare an appropriate response to Paradigm's complaint. For these reasons, we respectfully request that the Court grant our motion to enlarge the time within which to respond to plaintiff's complaint, by 12 days, to and including March 24, 2008.

Case 1:07-cv-00873-MMS

Document 9

Filed 03/06/2008

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Respectfully submitted,

JEFFREY S. BUCHOLTZ Acting Assistant Attorney General

JEANNE E. DAVIDSON Director

s/ Patricia M. McCarthy PATRICIA M. McCARTHY Assistant Director

s/ Joseph A. Pixley JOSEPH A. PIXLEY Attorney Commercial Litigation Branch Civil Division Department of Justice 1100 L Street, N.W. Attn: Classification Unit 8th Floor Washington, DC 20530 Tel. (202) 307-0843 Fax. (202) 307-0972 March 6, 2008 Attorneys for Defendant

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Case 1:07-cv-00873-MMS

Document 9

Filed 03/06/2008

Page 3 of 3

CERTIFICATE OF FILING

I hereby certify that on the 6th 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. Parties may access this filing through the Court's system.

s/Joseph A. Pixley

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