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

Case 1:07-cv-00056-EJD

Document 8

Filed 03/21/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS

) ) Plaintiff, ) ) v. ) ) THE UNITED STATES OF AMERICA, ) ) ) Defendant ) ____________________________________)

BASS MANAGEMENT, INC.,

Case No. 07-056C (Chief Judge Damich)

DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMNT OF TIME Pursuant to Rules 6(b)(1) and 6.1 of the United States Court of Federal Claims ("RCFC"), defendant, the United States, respectfully requests a 30 day enlargement of time, to and including April 25, 2007, to file a response to plaintiff's complaint. Presently defendant's response to the complaint is due no later than March 26, 2007. This is defendant's first request for an enlargement of time for this purpose. Defendant has consulted with counsel for plaintiff, and counsel for plaintiff has represented that plaintiff consents to our request for an enlargement of time. Plaintiff's complaint encompasses 26 pages and 155 paragraphs of allegations. Appended to the complaint are nine exhibits. Undersigned counsel and counsel for the Army Corps of Engineers, Vicksburg District, are continuing to collect information to allow the United States to respond adequately and responsibly to the detailed allegations contained in the complaint. Agency counsel is in the process of preparing a final and complete litigation report. We rely upon agency counsel to prepare a litigation report, pursuant to 28 U.S.C. § 520, concerning the case so that we may respond properly to actions filed against the United States.

Case 1:07-cv-00056-EJD

Document 8

Filed 03/21/2007

Page 2 of 3

Due to the varied and complex allegations involved, defendant's counsel will require additional time to review the final litigation report and time to obtain supervisory review for the preparation and filing of the Government's response. For the foregoing reasons, defendant respectfully requests that the Court grant its unopposed motion for an enlargement of time of 30 days, to an including April 25, 2007, within which to file a response to plaintiff's complaint.

Respectfully submitted,

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

KATHRYN A. BLEECKER Assistant Director s/ David M. Hibey DAVID M. HIBEY Trial Attorney Commercial Litigation Branch Civil Division Department of Justice 1100 L Street, N.W. Attn: Classification Unit 8th Floor Washington, D.C. 20530 Tel: (202) 307-0163 Fax: (202) 514-8624

March 21, 2007

Attorneys for Defendant

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Case 1:07-cv-00056-EJD

Document 8

Filed 03/21/2007

Page 3 of 3

CERTIFICATE OF FILING I hereby certify that on this 21st day of March, 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. Parties may access this filing through the Court's system. s/ David M. Hibey

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