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

Case 1:07-cv-00337-LJB

Document 15

Filed 10/23/2007

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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 November 28, 2007, within which to file its response to plaintiff's complaint. Defendant's response is currently due to be filed on October 29, 2007. This is defendant's third request for an enlargement of time for this purpose. Plaintiff's counsel does not oppose this request. As stated in our last motion, the Department of Veterans Affairs, Office of the Inspector General, conducted a review of plaintiff's claims on September 20, 2007, which materially advanced the parties' pursuing settlement of the case. Defendant shared a copy of the report with plaintiff. On October 15, 2007, defendant received plaintiff's response to the report with additional comments and information, which provides even more common ground with which the parties may continue to explore settling plaintiff's claims. 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

Case 1:07-cv-00337-LJB

Document 15

Filed 10/23/2007

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JEANNE E. DAVIDSON Director 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 October 23, 2007 Attorneys for Defendant

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Case 1:07-cv-00337-LJB

Document 15

Filed 10/23/2007

Page 3 of 3

CERTIFICATE OF FILING I hereby certify that on this 23rd day of October, 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