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

Case 1:07-cv-00773-SGB

Document 5

Filed 01/09/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS LOUISE HALL and GLENN GOULD, Plaintiffs, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) )

No. 07-773C (Judge Braden)

DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Defendant respectfully requests an enlargement of time of 60 days, to and including March 14, 2008, within which to file its response to plaintiff's complaint. due to be filed on January 14, 2008. Defendant's response is now This is defendant's first Defendant

request for an enlargement of time for this purpose.

has contacted counsel for plaintiffs, who has indicated that plaintiffs do not oppose this request. On December 28, 2007, counsel of record received the litigation report from the Department of the Interior. However,

counsel of record has not had an opportunity to prepare a response to the complaint. Thus, the enlargement is requested

because of counsel of record's workload, which includes discovery in the case of Edge Construction Co. v. United States, No. 06-635C, settlement negotiations in the cases of Hoh River Timber Co. v. United States, No. 06-418C, Kelly v. United States, No. 07-369C and State Automobile Mutual Insurance Company, Inc. v. United States, No. 07-516C, a response to a complaint in the case of GASA, Inc. v. United States, No. 01-642C, which is due on

Case 1:07-cv-00773-SGB

Document 5

Filed 01/09/2008

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January 15, 2008, and a response to the complaint in Hines v. United States, No. 07-623C, which is due on February 4, 2008. For these reasons, defendant respectfully requests that the Court grant its unopposed motion for a 60-day enlargement of time, to and including March 14, 2008, within which to file its response to plaintiff's complaint. Respectfully submitted, JEFFREY S. BUCHOLTZ Acting Assistant Attorney General JEANNE E. DAVIDSON Director

/s Brian M. Simkin BRIAN M. SIMKIN Assistant Director

/s L. Misha Preheim L. MISHA PREHEIM Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L St., NW Washington, D.C. 20530 Tele: (202) 305-3087 Fax: (202) 305-1571 January 9, 2008 Attorneys for Defendant

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Case 1:07-cv-00773-SGB

Document 5

Filed 01/09/2008

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CERTIFICATE OF FILING I hereby certify that on the 9th day of January, 2008, a copy of the foregoing "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. the Court's system. Parties may access this filing through

s/L. Misha Preheim