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

Case 1:07-cv-00174-CFL

Document 7

Filed 05/07/2007

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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 UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Defendant respectfully requests an enlargement of time of 39 days, to and including June 22, 2007, within which to file its answer or other responsive pleading that is currently due on May 14, 2007. This is defendant's first request for an enlargement of time for this purpose. Defendant has contacted plaintiff's counsel who has indicated that plaintiff does not oppose this request. The contract that is subject to dispute is almost 30 years old and the subject matter is complex. Agency counsel requires additional information from field offices that bear directly on the issue of the amount of potential liability. This information could take several more weeks until complete. Moreover, Government counsel will be out of the office on official travel from May 13 through May 17, 2007, when the answer would currently become due. Upon receipt of the necessary calculations, both parties will need some time to evaluate the possibility of settling the case. For these reasons, defendant respectfully requests that the Court grant its unopposed motion for a 39-day enlargement of time within which to file its answer or other responsive pleading.

Case 1:07-cv-00174-CFL

Document 7

Filed 05/07/2007

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 May 7, 2007 Attorneys for Defendant

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Case 1:07-cv-00174-CFL

Document 7

Filed 05/07/2007

Page 3 of 3

CERTIFICATE OF FILING I hereby certify that on this 7th day of May, 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