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

Case 1:07-cv-00778-LAS

Document 5

Filed 12/21/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS TODD R. FORBES, Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 07-778C (Judge Smith)

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 February 6, 2008, within which to file a response to the complaint filed by plaintiff, Todd R. Forbes. Our response is currently due on January 7, 2008. Plaintiff's counsel does not oppose our request. This is our first request for an enlargement of time for this purpose. Agency counsel needs additional time in which to collect documents. Due to the complexity of the issues involved in the case and the volume of material, the additional time requested is necessary for agency counsel to collect documents and for defendant's counsel to review the case file, coordinate with agency counsel, and to prepare an appropriate response to the complaint. Furthermore, defendant's counsel is scheduled to go on holiday leave from December 24, 2007 through January 3, 2008. For the foregoing reasons, we respectfully request that the Court grant our unopposed motion to enlarge the time within which to respond to the complaint, by 30 days, to and including

Case 1:07-cv-00778-LAS

Document 5

Filed 12/21/2007

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February 6, 2007. Respectfully submitted,

JEFFREY S. BUCHOLTZ Acting Assistant Attorney General

JEANNE E. DAVIDSON Director

DEBORAH A. BYNUM Assistant Director

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 December 21, 2007 Attorneys for Defendant

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Case 1:07-cv-00778-LAS

Document 5

Filed 12/21/2007

Page 3 of 3

CERTIFICATE OF FILING

I hereby certify that on the 21st day of December, 2007, a copy of the 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/Joseph A. Pixley

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