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

Case 1:07-cv-00099-EJD

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Filed 04/05/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS DECATUR HOTELS, L.L.C., Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 07-99C Chief Judge Edward J. Damich

DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Defendant respectfully requests an enlargement of time of 21 days, to and including May 1, 2007, within which to file its answer or otherwise respond to plaintiff's complaint. response currently is due on April 10, 2007. request for an enlargement for this purpose. Our

This is our first Plaintiffs' counsel

has authorized us to state that he does not object to this motion. As grounds for this motion, we state that, although we promptly forwarded the complaint to the General Services Administration together with a request for the litigation report that the agency is statutorily obligated to provide, we have not yet received the litigation report. Agency counsel has provided

a number of relevant documents but has advised us that he is still engaged in ascertaining whether any more relevant documents exist as well as attempting to speak with various individuals familiar with the circumstances alleged in the complaint. He has

indicated that he will not be able to prepare the ligation report

Case 1:07-cv-00099-EJD

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until this research is complete and estimates that an additional two weeks will be necessary to accomplish this. Based upon agency counsel's representations, we anticipate that the additional 21 days requested in this motion for an enlargement of time will be sufficient to allow us to receive the litigation report and to prepare and useful and accurate answer to the complaint. Accordingly, we respectfully request that the

Court grant this motion for an enlargement of time of 21 days, to and including May 1, 2007, within which to respond to plaintiffs' complaint. Respectfully submitted, PETER D. KEISLER Assistant Attorney General JEANNE E. DAVIDSON Director HILLARY A. STERN Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 1100 L Street, N.W. Washington, D.C. 20530 Tele: (202) 305-7561 Facsimile: (202) 305-7643 Attorneys for Defendant April 5, 2007

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Case 1:07-cv-00099-EJD

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Filed 04/05/2007

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