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

Case 1:07-cv-00337-LJB

Document 13

Filed 09/21/2007

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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 31 days, to and including October 29, 2007, within which to file its response to plaintiff's complaint. Defendant's response is currently due to be filed on September 28, 2007. This is defendant's second request for an enlargement of time for this purpose. Plaintiff's counsel does not oppose this request. Subsequent to the telephonic conference with the Court and plaintiff's counsel, the Department of Veterans Affairs, Office of the Inspector General ("IG"), conducted a review of plaintiff's claims. The IG concluded its report on September 20, 2007, and found that a substantial portion of plaintiff's claims had merit. Accordingly, defendant's counsel contacted plaintiff's counsel to advise him of the IG's recommendation and initiate settlement discussions. Plaintiff's counsel is out of the country until September 27, 2007, but agreed to discuss settlement upon his return. For these reasons, defendant respectfully requests that the Court grant its unopposed motion for a 31-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 13

Filed 09/21/2007

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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 September 21, 2007 Attorneys for Defendant

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Case 1:07-cv-00337-LJB

Document 13

Filed 09/21/2007

Page 3 of 3

CERTIFICATE OF FILING I hereby certify that on this 21st day of September, 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