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

Case 1:06-cv-00695-MMS

Document 21

Filed 08/03/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS BRICKWOOD CONTRACTORS, INC., Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 06-695C (Chief Judge Damich)

DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Pursuant to Rules 6(b) and 6.1 of the Rules of the United States Court of Federal Claims ("RCFC"), defendant, the United States, respectfully requests that the Court grant an enlargement of time of 30 days, to and including September 12, 2007, within which to prepare and file our answer. The Government's response currently is due on August 13, 2007. This is our first request for an enlargement of time for this purpose. Defendant's counsel contacted plaintiff's counsel, Scott J. Newton, and was informed that plaintiff does not object to this motion for enlargement of time. The enlargement of time requested is necessary because defendant's counsel will be out of the office from the afternoon of August 7, 2007 through the afternoon of August 13, 2007. Defendant's counsel will also be on medical leave from August 16, 2007 through at least August 27, 2007. Furthermore, agency counsel requires additional time to acquire the necessary information to respond to plaintiff's complaint. Accordingly, we respectfully request that the Court grant defendant's unopposed motion for an enlargement of time of 30 days, to and including September 12, 2007, in which to file the Government's response.

Case 1:06-cv-00695-MMS

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Filed 08/03/2007

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Respectfully Submitted, PETER D. KEISLER Assistant Attorney General JEANNE E. DAVIDSON Director /s/ DONALD E. KINNER DONALD E. KINNER Assistant Director /s/ MEREDYTH D. COHEN MEREDYTH D. COHEN 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) 353-7978 Fax: (202) 514-8624 August 3, 2007 Attorneys for Defendant

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Case 1:06-cv-00695-MMS

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Filed 08/03/2007

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CERTIFICATE OF SERVICE I certify under that on this 3rd day of August, 2007, a copy of the foregoing "DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME" was filed electronically. In 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/ MEREDYTH D. COHEN