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

Case 1:07-cv-00218-NBF

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Filed 08/07/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS GREAT LAKES DREDGE & DOCK CO., Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 07-218C (Judge Firestone)

DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Defendant respectfully requests an enlargement of time of 30 days, to and including September 17, 2007, within which to file its answer or other responsive pleading. Defendant's response to the complaint is presently due on August 16, 2007. This is defendant's second request for an enlargement of time for this purpose. Plaintiff's counsel does not oppose this request. The parties attempted to resolve their differences through alternative dispute resolution ("ADR") but did not reach agreement. On August 6, 2007, the ADR judge removed the case from the program. Accordingly, the Government must now re-focus on our response to the complaint. Additionally, Government counsel is responsible for five answers due in the following other cases: (1) Hillian Bros., Inc. v, United States, No. 07-326C (Fed. Cl.) on July 30, 2007 (enlargement requested); (2) Pennsauken Senior Towers Urban Renewal Assoc., LLC v. United States, No. 07-174C (Fed. Cl.) on August 21, 2007; and (3) Securitas Gmbh Werkschutz v. United States, Nos. 07-255C/256C/257C (Fed. Cl.) (three cases requiring three separate answers prior to consolidation) on August 24, 2007. In addition to the aforementioned cases, the Court directed

Case 1:07-cv-00218-NBF

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Filed 08/07/2007

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that the Government treat the case of TMI Mgmt. Systems, Inc. v. United States, 07-407 (Fed. Cl.), on an expedited schedule, akin to a bid protest case, and file our brief by August 31, 2007, and scheduled oral argument on September 4, 2007. Government counsel will also be attending a course at the Department of Justice's National Advocacy Center in Columbia, South Carolina, from September 10 through September 12, 2007. For these reasons, defendant respectfully requests that the Court grant its unopposed motion for a 30-day 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/ Donald E. Kinner DONALD E. KINNER 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 August 7th, 2007 Attorneys for Defendant

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Case 1:07-cv-00218-NBF

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Filed 08/07/2007

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CERTIFICATE OF FILING I hereby certify that on this 7th day of August, 2007, 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. The parties may access this filing through the Court's system.

s/ Armando Rodriguez-Feo