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

Case 1:07-cv-00337-LJB

Document 17

Filed 11/19/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS CCS INDUSTRIAL SALES, INC., Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 07-337C (Judge Bush)

DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Defendant respectfully requests an enlargement of time of 30 days, to and including December 28, 2007, within which to file its response to plaintiff's complaint. Defendant's response is currently due to be filed on November 28, 2007. This is defendant's fourth request for an enlargement of time for this purpose. Plaintiff's counsel does not oppose this request. As stated in our last motion, the parties agreed to explore settling the case, and have since negotiated a proposed settlement. Defendant will forward the proposal to the authorized representative of the United States Attorney General. See 28 C.F.R. Part 0, Subpart Y. Additionally, Government counsel will be out of the office from November 21, 2007, through December 4, 2007. For these reasons, defendant respectfully requests that the Court grant its unopposed motion for a 30-day enlargement of time within which to file its response to plaintiff's complaint. Respectfully submitted, PETER D. KEISLER Assistant Attorney General JEANNE E. DAVIDSON Director

Case 1:07-cv-00337-LJB

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Filed 11/19/2007

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s/ Steven J. Gillingham STEVEN J. GILLINGHAM Assistant Director s/ Armando A. Rodriguez-Feo ARMANDO A. RODRIGUEZ-FEO 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) 307-3390 Fax: (202) 514-8624 November 19, 2007 Attorneys for Defendant

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Case 1:07-cv-00337-LJB

Document 17

Filed 11/19/2007

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CERTIFICATE OF FILING I hereby certify that on this 19th day of November, 2007, a copy of the foregoing "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. The parties may access this filing through the Court's system.

s/ Armando A. Rodriguez-Feo