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

Case 1:07-cv-00338-NBF

Document 7

Filed 07/23/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS

EDWARD F. CHANNELL et al., Plaintiffs, v. THE UNITED STATES, Defendant.

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No. 07-338C (Judge Nancy B. Firestone)

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 45-day enlargement of time, to and including September 13, 2007, to file a response to the complaint. Our response is currently due on July 30, 2007. This is defendant's first request for an enlargement of time for this purpose. Defendant's counsel has spoken with plaintiff's counsel about this enlargement of time. Plaintiff's counsel stated that he does not oppose this enlargement. The enlargement is requested because the undersigned counsel of record for defendant has not received a litigation report from the interested agency, the Broadcasting Board of Governors, as required by 28 U.S.C. § 520. The additional time is necessary to allow sufficient time for agency counsel to prepare the litigation report and for counsel of record to review the litigation report and prepare the Government's response to the complaint. For the foregoing reasons, defendant respectfully requests that the Court grant its motion for an enlargement of time of 45 days, to and including September 13, 2007, within which to file a response to the plaintiff's complaint.

Case 1:07-cv-00338-NBF

Document 7

Filed 07/23/2007

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Respectfully submitted,

PETER D. KEISLER Assistant Attorney General JEANNE E. DAVIDSON Director

/s/ Todd M. Hughes TODD M. HUGHES Deputy Director /s/ Ellen M. Lynch ELLEN M. LYNCH Trial Attorney Commercial Litigation Branch Civil Division U.S. Department of Justice Attn: Classification Unit 1100 L Street, N.W., 8th Floor Washington, D.C. 20530 Tel: (202) 353-7994 Fax: (202) 514-8624 July 23, 2007 Attorneys for Defendant

Case 1:07-cv-00338-NBF

Document 7

Filed 07/23/2007

Page 3 of 3

Certificate of Filing I hereby certify that on this 23rd day of July, 2007, a copy of "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/ Ellen M. Lynch Ellen M. Lynch