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

Case 1:07-cv-00272-ECH

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Filed 08/13/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS MARK G. ABBEY, et al., Plaintiffs, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 07-272C (Judge Emily C. Hewitt)

DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Defendant respectfully requests an enlargement of time of 21 days, to and including September 4, 2008, within which to file its answer or otherwise respond to the complaint. Our response

currently is due on August 14, 2008, the Court having denied our dispositive motions by decision dated July 31, 2008. This is our

first request for an enlargement of time for this purpose after the Court's ruling on our dispositive motion. Plaintiffs'

counsel has authorized us to state that he does not object to this motion. As grounds for this motion, we state that counsel of record for the United States is out of the office on previouslyscheduled leave and will return to the office on August 21, 2008. Upon counsel's return, she will work diligently with the agency to prepare defendant's answer to the complaint. Counsel

anticipates that the additional 21 days requested in this motion will be sufficient to allow us to prepare the answer to the

Case 1:07-cv-00272-ECH

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complaint. Accordingly, we respectfully request that the Court grant this motion for an enlargement of time of 21 days, to and including September 4, 2008, within which to respond to plaintiffs' complaint. Respectfully submitted, GREGORY G. KATSAS Assistant Attorney General s/ Jeanne E. Davidson JEANNE E. DAVIDSON Director s/Hillary A. Stern by Jane W. Vanneman HILLARY A. STERN Senior Trial Counsel Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 1100 L Street, N.W. Washington, D.C. 20530 Tele: (202) 616-0177 Facsimile: (202) 305-7643 Attorneys for Defendant August 13, 2008

Case 1:07-cv-00272-ECH

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CERTIFICATE OF SERVICE I hereby certify that on this 13th day of August, 2008, 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. Parties may access this filing through the Court's system.