Free Motion for Extension of Time to File Response/Reply - District Court of Federal Claims - federal

Case 1:07-cv-00032-CCM

Document 13

Filed 06/29/2007

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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 July 9, 2007 date by which our reply to plaintiff's opposition to our motion to dismiss is due, be enlarged by 10 days, to and including July 19, 2007. This is our first requested enlargement for this purpose. We consulted with plaintiff's counsel of record, who advised us that our request is not opposed. We respectfully submit that the requested enlargement is necessary to obtain information needed to permit the Government to properly reply to plaintiff's brief. Plaintiff's brief is of considerable length, and the review and development of our reply requires consultation and coordination with the Department of the Treasury. In addition, prior to and during the period covered by this requested enlargement, our counsel of record will be engaged in other litigation matters pending before this Court, including the preparation of post-trial briefing in Astoria Federal v. United States, No. 95-468, and before the Court of International Trade, in Dorbest Limited, et. al v. United States, No. 05-0003. For the foregoing reasons, we respectfully request that this motion be granted.

Case 1:07-cv-00032-CCM

Document 13

Filed 06/29/2007

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Respectfully submitted, PETER D. KEISLER Assistant Attorney General s/Jeanne E. Davidson by: s/ Kenneth M. Dintzer
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: June 29, 2007 Attorneys for Defendant

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Case 1:07-cv-00032-CCM

Document 13

Filed 06/29/2007

Page 3 of 3

CERTIFICATE OF FILING I hereby certify that on June 29, 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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