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

Case 1:07-cv-00222-SGB

Document 6

Filed 05/22/2007

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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 45-day enlargement of time within which to respond to plaintiff's complaint. Defendant's response to plaintiff's complaint is This is defendant's first request The enlargement would make Counsel for plaintiff

currently due by June 5, 2006.

for an enlargement for this purpose.

defendant's response due by July 20, 2007.

has represented to counsel for defendant that plaintiff consents to this request. We request the enlargement because, first, the parties are engaged in settlement discussions, and relieving defendant of the burden of responding to the complaint for the period requested would facilitate those discussions. Second, counsel for

defendant will be out of the office during the week of June 25, 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 July 20, 2007.

Case 1:07-cv-00222-SGB

Document 6

Filed 05/22/2007

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Respectfully submitted, PETER D. KEISLER Assistant Attorney General JEANNE E. DAVIDSON Director

s/Donald E. Kinner 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 May 22, 2007 Attorneys for Defendant

2

Case 1:07-cv-00222-SGB

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Filed 05/22/2007

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CERTIFICATE OF SERVICE I hereby certify that on May 22, 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