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

Case 1:07-cv-00291-CCM

Document 6

Filed 07/02/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS IMS ENGINEERS-ARCHITECTS, P.C., ) ) ) ) ) No. 07-0291C ) ) (Judge Christine O.C. Miller) ) ) )

Plaintiff, v. THE UNITED STATES, Defendant.

DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME Pursuant to Rules 6(b)(1) and 6.1 of the United States Court of Federal Claims (RCFC), defendant, the United States, respectfully requests an enlargement of time of twenty-one days, to and including July 30, 2007, to file a response to the complaint. Defendant's response currently is due on July 9, 2007. This is defendant's first request for an enlargement for this purpose. Defendant has consulted with counsel for the plaintiff and counsel for the plaintiff has represented that the plaintiff does not oppose this request for an enlargement of time. Defendant promptly sent to the involved agency, the U.S. Army ("Army"), a copy of the complaint with a request for a litigation report and suggested response to the complaint, pursuant to 28 U.S.C. § 520. Additional time is needed for the Army to investigate the allegations made in the complaint, finalize the litigation report, and provide a suggested response to the complaint. Defendant's counsel will require additional time to review the litigation report and supporting documentation, the suggested response to the complaint, to consult with agency counsel and other Government attorneys, and to prepare and file the Government's response to the complaint.

Case 1:07-cv-00291-CCM

Document 6

Filed 07/02/2007

Page 2 of 3

For the foregoing reasons, defendant respectfully requests that the Court grant this motion for enlargement of time of twenty-one days, to and including July 30, 2007, within which to file a response to the plaintiff's complaint. Respectfully submitted, PETER D. KEISLER Assistant Attorney General JEANNE E. DAVIDSON Director s/ Deborah A. Bynum DEBORAH A. BYNUM Assistant Director s/ Robert C. Bigler ROBERT C. BIGLER Trial Attorney Commercial Litigation Branch Civil Division Department of Justice 1100 L St., N.W. Attn: Classification Unit 8th Floor Washington, D.C. 20530 Tele: (202) 307-0315 Fax: (202) 514-8624 July 2, 2007

Case 1:07-cv-00291-CCM

Document 6

Filed 07/02/2007

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that on this 2nd day of July 2007, a copy of the foregoing "DEFENDANT'S UNOPPOSED MOTION FOR 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/ Robert C. Bigler