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

Case 1:07-cv-00174-CFL

Document 9

Filed 06/07/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS PENNSAUKEN SENIOR TOWERS URBAN RENEWAL ASSOCIATES LLC & HOUSING AUTHORITY OF THE TOWNSHIP OF PENNSAUKEN, Plaintiffs, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) ) ) )

No. 07-174C (Judge Lettow)

DEFENDANT'S SECOND UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Defendant respectfully requests an additional enlargement of time of 60 days, to and including August 21, 2007, within which to file its answer or other responsive pleading that is currently due on June 22, 2007. This is defendant's second request for an enlargement of time for this purpose. Defendant previously sought an extension of 39 days which this Court approved on May 11, 2007. Defendant has contacted plaintiff's counsel who has indicated that plaintiff does not oppose this request. As stated previously, the contract that is subject to dispute is almost 30 years old and the subject matter is complex. But both sides have discussed the possibility of resolving this case and, at this time, Plaintiff agrees that the interests of justice would be best served by allowing the Government more time to research and gather the necessary information to consider its claim. For these reasons, defendant respectfully requests that the Court grant its unopposed motion for a 60-day enlargement of time within which to file its answer or other responsive pleading.

Case 1:07-cv-00174-CFL

Document 9

Filed 06/07/2007

Page 2 of 3

Respectfully submitted, PETER D. KEISLER Assistant Attorney General JEANNE E. DAVIDSON Director s/ Brian M. Simkin BRIAN M. SIMKIN 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 7, 2007 Attorneys for Defendant

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Case 1:07-cv-00174-CFL

Document 9

Filed 06/07/2007

Page 3 of 3

CERTIFICATE OF FILING I hereby certify that on this 7th day of June, 2007, a copy of the foregoing "DEFENDANT'S SECOND 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