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

Case 1:07-cv-00222-SGB

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Filed 07/06/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS TRIGEANT, LTD., Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) )

No. 07-222C (Judge Braden)

DEFENDANT'S CONSENT MOTION FOR AN EXTENSION OF TIME WITHIN WHICH TO RESPOND TO PLAINTIFF'S COMPLAINT Defendant, the United States, respectfully requests a 42-day enlargement of time within which to respond to plaintiff's complaint. Defendant's response to plaintiff's complaint is This is defendant's second The enlargement Counsel

currently due by July 20, 2007.

request for an enlargement for this purpose.

would make defendant's response due by August 31, 2007.

for plaintiff has represented to counsel for defendant that plaintiff consents to this request. We request the enlargement because, first, the parties have made progress toward settlement: plaintiff has indicated a settlement figure that lead counsel for defendant intends to recommend to the Attorney General. The process of making that

recommendation and obtaining the Attorney General's position, however, may take approximately three weeks. Second, lead

counsel for defendant is engaged in finishing discovery in The TAS Group v. Department of Justice, a case scheduled to be heard by the United States Civilian Board of Contract Appeals beginning

Case 1:07-cv-00222-SGB

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on August 20, 2007.

For these reasons, defendant respectfully

requests that the Court enlarge the time for defendant to respond to plaintiff's complaint by 45 days, to August 31, 2007. Respectfully submitted, PETER D. KEISLER Assistant Attorney General JEANNE E. DAVIDSON Director

s/Donald E. Kinner by s/Brian M. Simkin DONALD E. KINNER Assistant Director

s/Timothy P. McIlmail TIMOTHY P. MCILMAIL Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L Street, N.W. Washington, D.C. 20530 Telephone: (202) 616-0342 Facsimile: (202) 514-7965 July 6, 2007 Attorneys for Defendant

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Case 1:07-cv-00222-SGB

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CERTIFICATE OF SERVICE I hereby certify that on July 6, 2007, the foregoing Defendant's Consent Motion For An Extension Of Time Within Which To Respond To Plaintiff's Complaint 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. may access this filing through the Court's system. Parties

s/Timothy P. McIlmail