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

Case 1:07-cv-00849-ECH

Document 13

Filed 04/23/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS GRAND ACADIAN, INC. Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 07-849C (Judge Hewitt)

DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME Pursuant to Rule 6.1 of the Rules of the United States Court of Federal Claims ("RCFC"), defendant, the United States, respectfully requests a 21-day extension of time, to and including May 20, 2008, to file a response to the amended complaint. The answer currently is due on April 29, 2008. This is our first request for an enlargement of time for this purpose. Counsel for the parties have discussed this motion and its request for relief, and plaintiff's counsel has represented that plaintiff does not oppose this request. The requested enlargement is necessary because defendant's counsel has been out of the office to perform family responsibilities associated with the birth of a child. We anticipate that the additional 21 days will provide sufficient time for defendant to prepare the response and to confer and to coordinate with agency counsel.

Case 1:07-cv-00849-ECH

Document 13

Filed 04/23/2008

Page 2 of 3

For the foregoing reasons, we respectfully request that the Court grant this unopposed motion for a 21-day enlargement of time, to and including May 20, 2008, for the United States to file its answer to the amended complaint. Respectfully submitted,

JEFFREY S. BUCHOLTZ Acting Assistant Attorney General

JEANNE E. DAVIDSON Director

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

s/Douglas G. Edelschick DOUGLAS G. EDELSCHICK Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L. Street, N.W. Washington, DC 20530 Tel: (202) 353-9303 April 23, 2008 Attorneys for Defendant

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Case 1:07-cv-00849-ECH

Document 13

Filed 04/23/2008

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that on April 23, 2008, a copy of foregoing "DEFENDANT'S UNOPPOSED MOTION FOR 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/Douglas G. Edelschick

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