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

Case 1:07-cv-00008-MBH

Document 10

Filed 03/01/2007

Page 1 of 3

IN THE UNITED STATES COURT OF FEDERAL CLAIMS LARRY S. ANDERSON, et al., ) ) ) ) ) 1:07-cv-08-MBH ) ) (Judge Horn) ) ) )

Plaintiffs, v. THE UNITED STATES, Defendant.

DEFENDANT'S 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 fifteen day enlargement of time, to and including March 20, 2007, to file a response to the complaint. Defendant's response is currently due on March 5, 2007. This is defendant's first request for an enlargement for this purpose. Defendant has consulted with counsel for the plaintiffs and counsel for the plaintiffs has represented that the plaintiffs do not oppose this request for an enlargement of time. Defendant has sent the Department of the Navy ("Navy") a copy of the complaint with a request for a litigation report and suggested response to the complaint, pursuant to 28 U.S.C. § 520. Additional time is needed for the Navy to investigate the duties performed by the plaintiffs and for the Navy to prepare a litigation report and a suggested response to the complaint. Defendant's counsel will require additional time to study the litigation report, its supporting documentation, and the suggested response to the complaint, to consult with agency counsel and other Government attorneys, and to prepare and file the Government's response to the complaint, following mandatory supervisory review.

Case 1:07-cv-00008-MBH

Document 10

Filed 03/01/2007

Page 2 of 3

For the foregoing reasons, defendant respectfully requests that the Court grant this motion for enlargement of time of fifteen days, to and including March 20, 2007, within which to file a response to the plaintiffs' complaint. Respectfully submitted, PETER D. KEISLER Assistant Attorney General JEANNE E. DAVIDSON Acting Director s/ Kathryn A. Bleecker KATHRYN A. BLEECKER Assistant Director s/ Robert C. Bigler ROBERT C. BIGLER Trial Attorney Commercial Litigation Branch Civil Division Department of Justice 1100 L St., N.W. Attn: Classification Unit 8th Floor Washington, D.C. 20530 Tele: (202) 307-0315 Fax: (202) 514-8624 March 1, 2007

Case 1:07-cv-00008-MBH

Document 10

Filed 03/01/2007

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that on this 1st day of March 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. The parties may access this filing through the Court's system.

s/ Robert C. Bigler