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

Case 1:07-cv-00145-TCW

Document 6

Filed 04/25/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS

STOUT ROAD ASSOCIATES, INC. t/a HILTON PHILADELPHIA CITY AVENUE, Plaintiff, v. THE UNITED STATES, Defendant.

) ) ) ) ) No. 07-145C ) (Judge Wheeler) ) ) ) )

DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Pursuant to Rules 6(b) and 6.1 of the Rules of the United States Court of Federal Claims ("RCFC"), defendant, the United States, respectfully requests a 30-day enlargement of time, to and including June 7, 2007, to file a response to the complaint. Our response is currently due on May 7, 2007. This is defendant's first request for an enlargement of time for this purpose. Defendant's counsel has spoken with plaintiff's counsel about this enlargement of time, who stated that he does not oppose this enlargement. The enlargement is requested because the undersigned counsel of record for defendant has not yet received a litigation report from the interested agency, the Defense Supply Center Richmond, as required by 28 U.S.C. § 520. Upon receipt of the complaint, defendant's counsel promptly sent a copy to the agency with a request for a litigation report pursuant to 28 U.S.C. § 520. The additional time is necessary to allow sufficient time for agency counsel to complete the litigation report and for counsel of record to review the litigation report and prepare the Government's response to the complaint. For the foregoing reasons, defendant respectfully requests that the Court grant its motion for an enlargement of time of 30 days, to and including June 7, 2007, within which to file a

Case 1:07-cv-00145-TCW

Document 6

Filed 04/25/2007

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response to the plaintiff's complaint. Respectfully submitted,

PETER D. KEISLER Assistant Attorney General JEANNE E. DAVIDSON Director

/s/ Mark A. Melnick MARK A. MELNICK Assistant Director /s/ Carrie A. Dunsmore CARRIE A. DUNSMORE Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 1100 L Street, N.W., 8th Floor Washington, D.C. 20530 Tel: (202) 305-7576 Fax: (202) 514-8624 April 25 , 2007 Attorneys for Defendant

Case 1:07-cv-00145-TCW

Document 6

Filed 04/25/2007

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Certificate of Filing I hereby certify that on this 25th day of April, 2007, a copy of the 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. Parties may access this filing through the Court's system. /s/Carrie A. Dunsmore Carrie A. Dunsmore