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

Case 1:07-cv-00256-MMS

Document 9

Filed 06/06/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS

SECURITAS GmbH WERKSCHUTZ, Plaintiff, v. THE UNITED STATES, Defendant.

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Case No. 07-256C (Judge Sweeney)

DEFENDANT'S MOTION FOR AN ENLARGEMENT OF TIME Defendant respectfully requests an enlargement of time of 60 days, to and including August 24, 2007, within which to file its answer or other responsive pleading. Defendant's response to each complaint is presently due on June 25, 2007. This is defendant's first request for an enlargement of time for this purpose. Plaintiff's counsel does not oppose this request. This motion is necessary to enable counsel to adequately prepare the Government's responses, given the cases' complexity, and counsel's other responsibilities. These related cases arise under the same security services contract, with different theories of liability, entered into between the United States and SECURITAS for military installations in Germany. The Government is presently gathering the necessary information to properly answer the complaint and assert counterclaims and defenses. However, during the requested period of enlargement, lead counsel will be out of the office on military reserve duty for 2 weeks in mid-July, 2007. Moreover, he has filings due in the following cases:(1) JOA Construction Co. v. United States, Fed. Cl. No. 1:07-cv-00160, on June 11, 2007; (2) Pennsauken Senior Towers Urban Renewal Associates, LLC, et al. v. United States, Fed. Cl. No. 1:07-cv-00174, on June 22, 2007; and (3) Aliamanu Conservation Partners, Inc. v. United States, Fed. Cl. No. 1:07-cv-00134 on June 26, 2007. Undersigned counsel will not be able to dedicate the requisite time and resources until

Case 1:07-cv-00256-MMS

Document 9

Filed 06/06/2007

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July, 2007, at the earliest. For these reasons, defendant respectfully requests that the Court grant its motion for a 60day enlargement of time within which to file its answer or other responsive pleading. Respectfully submitted, PETER D. KEISLER Assistant Attorney General JEANNE E. DAVIDSON Director s/ Steven J. Gillingham STEVEN J. GILLINGHAM Assistant Director s/ Armando 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 June 6, 2007 Attorneys for Defendant

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Case 1:07-cv-00256-MMS

Document 9

Filed 06/06/2007

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CERTIFICATE OF FILING I hereby certify that on this 6th day of June 2007, a copy of the foregoing "DEFENDANT'S 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 Rodriguez-Feo