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

Case 1:07-cv-00126-LMB

Document 9

Filed 04/06/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS SI-NOR INCORPORATED, a California corporation, Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) )

No. 07-126C (Judge Baskir)

DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME Pursuant to Rules 6(b)(1) 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 May 29, 2007, within which to file a response to the complaint. April 27, 2007. The response to the complaint is currently due This is defendant's first request for an Plaintiff's counsel has represented that

enlargement of time.

plaintiff does not oppose this motion. The enlargement is requested because the undersigned counsel of record for defendant has not yet received a litigation report from the Department of the Air Force ("Air Force") as required under 28 U.S.C. § 520(b). Undersigned counsel has been informed

by the Air Force that, despite counsel's prompt request for a litigation report, the Air Force will be unable to generate such a report in time to respond to the complaint by the current deadline. 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

Case 1:07-cv-00126-LMB

Document 9

Filed 04/06/2007

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Government's response to the complaint. For the foregoing reasons, defendant respectfully requests that the Court grant this motion for an enlargement of time by 30 days, to and including May 29, 2007, within which to file a response to the complaint. Respectfully submitted, PETER D. KEISLER Assistant Attorney General JEANNE E. DAVIDSON Director s/Deborah A. Bynum DEBORAH A. BYNUM Assistant Director s/ A. Bondurant Eley A. BONDURANT ELEY Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L Street, NW Washington, D.C. 20530 Tel: (202) 616-5824 Fax: (202) 514-8624 April 6, 2007 Attorneys for Defendant

Case 1:07-cv-00126-LMB

Document 9

Filed 04/06/2007

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CERTIFICATE OF FILING I hereby certify that on this 6th day of April, 2007, a copy of the foregoing "MOTION FOR EXTENSION OF TIME TO ANSWER COMPLAINT" 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. through the Court's system. Parties may access this filing

s/ A. Bondurant Eley A. BONDURANT ELEY