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

Case 1:99-cv-02051-LAS

Document 20

Filed 01/30/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS ) ) ) ) ) ) ) ) ) ) ) )

ATHEY, ROBERT M., et al., Plaintiffs, v.

C.A. No. 99-2051C (Senior Judge Smith)

THE UNITED STATES, Defendant.

DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME Pursuant to Rule 6.1 of the Rules of the United States Court of Federal Claims, defendant, the United States, respectfully requests an enlargement of time of eight days, to and including February 9, 2007, within which to file a responsive pleading to Plaintiffs' Third Amended Complaint. Plaintiffs filed a Motion for Leave to File Plaintiffs' Third Amended Complaint on December 22, 2006. Defendant's response is currently due to be filed on February 1, 2007. This is defendant's first request for an enlargement of time for this purpose. Counsel for plaintiffs, Ira Lechner, has represented that plaintiffs do not oppose this eight day enlargement of time. The additional time is necessary because a recently hired attorney with the
United States Department of Veterans Affairs has just taken over the responsibility as agency counsel for this case. Therefore, she needs some additional time to familiarize herself with the facts and legal issues involved in this litigation. The eight day enlargement will provide the Government with the time necessary to consider the amended complaint and draft our response with the assistance of informed agency counsel. For these reasons, defendant respectfully requests that the Court grant the motion for an enlargement of time to file the Government's response, to and including February 9, 2007.

Case 1:99-cv-02051-LAS

Document 20

Filed 01/30/2007

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Respectfully submitted,

PETER D. KEISLER Assistant Attorney General

DAVID M. COHEN Director

/s/ Kathryn A. Bleecker KATHRYN A. BLEECKER Assistant Director OF COUNSEL: /s/ Sharon A. Snyder SHARON A. SNYDER Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 1100 L St., NW, 8th Floor Washington, D.C. 20530 (202) 307-0361 Attorneys for Defendant

KATE M. RYAN General Attorney U.S. Department of Veterans Affairs 801 Vermont Ave. N.W. Washington, D.C.

January 30, 2007

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Case 1:99-cv-02051-LAS

Document 20

Filed 01/30/2007

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CERTIFICATE OF FILING I hereby certify that on January 30, 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/ Sharon A. Snyder