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

Case 1:07-cv-00134-SGB

Document 6

Filed 04/20/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS ALIAMANU CONSERVATION PARTNERS, INC, Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) )

No. 07-134C (Judge Francis M. Allegra)

DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Defendant respectfully requests an enlargement of time of 35 days, to and including June 1, 2007, within which to file its answer or other responsive pleading that is currently due on April 27, 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 over 15 years old with several modifications, the subject matter is complex, and the Government is contemplating a counterclaim. Government counsel recently joined the Department of Justice on March 5, 2007. He has several other responses due in the next several weeks for the following matters in this Court: (1) Paige v. United States, Fed. Cl. No. 1:07-cv-00128-RHH, on April 27, 2007; (2) Phillips v. United States, Fed. Cl. No. 1:07-cv-00149-CFL, on May 4, 2007; and JOA Construction Co. V. United States, Fed. Cl. No. 1:07-cv-00160-EGB, on May 11. Additionally, agency counsel will be on travel and unavailable from April 27 through May 7, 2007 while Government counsel will be out of the office on official travel from May 13 through May 17, 2007. For these reasons, defendant respectfully requests that the Court grant its unopposed

Case 1:07-cv-00134-SGB

Document 6

Filed 04/20/2007

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motion for a 35-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/ Steven J. Gillingham STEVEN J. GILLINGHAM 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 April 20, 2007 Attorneys for Defendant

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Case 1:07-cv-00134-SGB

Document 6

Filed 04/20/2007

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CERTIFICATE OF FILING I hereby certify that on this 20th day of April, 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