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

Case 1:07-cv-00013-MCW

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Filed 03/08/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS

ARIZONA DEPARTMENT OF ECONOMIC SECURITY, Plaintiff, v. THE UNITED STATES, Defendant.

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No. 07-13C (Judge Williams)

DEFENDANT'S FIRST UNOPPOSED MOTION FOR ENLARGEMENT OF TIME

Pursuant to Rule 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 11, 2007, to file a response to the complaint. Defendant's response is currently due on March 12, 2007. This is defendant's first request for an enlargement for this purpose. Defendant has consulted with counsel for plaintiff and counsel for plaintiff has represented that plaintiff does not oppose this request for an enlargement of time. Defendant seeks this enlargement because the parties have held preliminary discussions regarding settlement, and the defendant would like to continue to explore the possibility of settling this case before we file a response to plaintiff's complaint. An enlargement of 30 days within which to respond will allow us to continue to investigate thoroughly the possibilities for settlement, or, if need be, prepare a response to plaintiff's complaint.

Case 1:07-cv-00013-MCW

Document 5

Filed 03/08/2007

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For the foregoing reasons, we respectfully request that our motion be granted.

Respectfully submitted, PETER D. KEISLER Assistant Attorney General JEANNE E. DAVIDSON Director s/ Donald E. Kinner DONALD E. KINNER Assistant Director

s/ Tara Kilfoyle TARA KILFOYLE Trial Attorney Commercial Litigation Branch Civil Division 1100 L St., N.W. Attn: Classification Unit 8th Floor Washington, D.C. 20530 Tele: (202) 305-1709 Fax: (202) 307-0972

March 8, 2007

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Case 1:07-cv-00013-MCW

Document 5

Filed 03/08/2007

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CERTIFICATE OF SERVICE I hereby certify that on this 8th day of March 2007, a copy of the foregoing "DEFENDANT'S FIRST 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. The parties may access this filing through the Court's system.

s/ Tara Kilfoyle