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

Case 1:07-cv-00160-EGB

Document 6

Filed 06/11/2007

Page 1 of 3

IN THE UNITED STATES COURT OF FEDERAL CLAIMS J.O.A. CONSTRUCTION CO., INC., Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 07-160C (Judge Bruggink)

DEFENDANT'S SECOND UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Defendant respectfully requests an enlargement of time of 30 days, to and including July 11, 2007, within which to file its answer or other responsive pleading. Defendant's response to the complaint is presently due on June 11, 2007. This is defendant's second request for an enlargement of time for this purpose. The Court previously granted a 31-day extension on May 22, 2007. Plaintiff's counsel does not oppose this request. This motion is necessary to enable counsel to prepare adequately the Government's response given the nature of this case, as well as counsel's other responsibilities. There are still some outstanding items with the agency that lead counsel needs to resolve in order to properly respond to plaintiff's complaint. Unfortunately, despite efforts to address the issues in order to accommodate a responsive filing by today, additional time is required to coordinate with agency representatives, some of whom are away on official travel, concerning these issues. As soon as these issues are resolved, the Government will file its response to the complaint. For these reasons, defendant respectfully requests that the Court grant its motion for a 30day enlargement of time within which to file its answer or other responsive pleading. Respectfully submitted, PETER D. KEISLER Assistant Attorney General

Case 1:07-cv-00160-EGB

Document 6

Filed 06/11/2007

Page 2 of 3

JEANNE E. DAVIDSON Director s/ Martin F. Hockey, Jr. MARTIN F. HOCKEY, JR. 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 11, 2007 Attorneys for Defendant

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Case 1:07-cv-00160-EGB

Document 6

Filed 06/11/2007

Page 3 of 3

CERTIFICATE OF FILING I hereby certify that on this 11th 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