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

Case 1:07-cv-00815-TCW

Document 7

Filed 01/10/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS CALL HENRY, INC., Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 07-815C (Judge Wheeler)

DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME Pursuant to Rule 6.1 of the Rules of the United States Court of Federal Claims, defendant, the United States, respectfully requests a 45-day extension of time, to and including March 7, 2008, to respond to the complaint filed by plaintiff, Call Henry, Inc. Our response to the complaint currently is due on January 22, 2008. This is our first request for an enlargement of time for this purpose. Counsel for the parties have discussed this motion and the requested enlargement of time. Plaintiff's counsel has represented that plaintiff does not oppose a 45-day enlargement. The requested 45-day enlargement is necessary to promote discussions between the parties concerning the possibility of resolving this dispute short of further litigation. In addition, the requested 45-day extension will avoid the unnecessary expenditure of resources by the parties and the Court.

Case 1:07-cv-00815-TCW

Document 7

Filed 01/10/2008

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For these reasons, we respectfully request that the Court grant this motion for a 45-day enlargement of time, to and including March 7, 2008, for the United States to respond to the complaint. Respectfully submitted,

JEFFREY S. BUCHOLTZ Acting Assistant Attorney General

JEANNE E. DAVIDSON Director

s/Patricia M. McCarthy PATRICIA M. MCCARTHY 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 January 10, 2007 Attorneys for Defendant

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Case 1:07-cv-00815-TCW

Document 7

Filed 01/10/2008

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CERTIFICATE OF SERVICE I hereby certify that on January 10, 2007, 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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