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

Case 1:07-cv-00032-CCM

Document 6

Filed 03/08/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS

BANK OF GUAM, Plaintiff, v.

THE UNITED STATES, Defendant.

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No. 07-32C (Judge Braden)

DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME
Defendant, the United States, pursuant to Rule 6 of the Rules of the United States Court of Federal Claims, respectfully requests that the March 19, 2007 date by which our response to plaintiff's complaint is due, be enlarged by 30 days, to and including April 18, 2007. This is our first requested enlargement for this purpose. We consulted with plaintiff's counsel of record, who advised us that our request will not be opposed. We respectfully submit that the requested enlargement is necessary to obtain information needed to permit the Government properly to respond to the complaint. Plaintiff's complaint was received by our counsel of record on January 30, 2007. Since then, the United States Department of Treasury, Bureau of Public Debt, has been investigating the complaint's allegations and working upon the preparation of the litigation report prescribed by 28 U.S.C. § 520. The complaint alleges matters involving transactions occurring several years ago, other agencies, and a broad variety of

issues. The review of, and preparation of our response to, the complaint, require communication and coordination beyond the Bureau of Public Debt. In addition, prior to and during the period covered by this requested enlargement, our counsel has been engaged in other matters pending before this Court, preparing for trials scheduled in National Australia Bank v. United States, No.

Case 1:07-cv-00032-CCM

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Filed 03/08/2007

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99-690C (matter is still pending but trial scheduled for Feb. 5, 2007 is cancelled) and in Astoria Federal v. United States, No. 95-468 (six-week trial commences April 19, 2006). For the foregoing reasons, we respectfully request that this motion be granted. Respectfully submitted, PETER D. KEISLER Assistant Attorney General s/Jeanne E. Davidson JEANNE E. DAVIDSON Director s/Brian A. Mizoguchi BRIAN A. MIZOGUCHI Trial Attorney Commercial Litigation Branch Civil Division United States Department of Justice Attn.: Classification Unit 8th Flr. 1100 L Street, N.W. Washington, D.C. 20530
Tel: 202.307.0282 Telecopier:(202) 305-7643 Dated: March 8, 2007 Attorneys for Defendant

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Case 1:07-cv-00032-CCM

Document 6

Filed 03/08/2007

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CERTIFICATE OF FILING I hereby certify that on March 8, 2007, a copy of the foregoing "DEFENDANT"S UNOPPOSED MOTION FOR 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/Brian A. Mizoguchi

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