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

Case 1:06-cv-00449-TCW

Document 25

Filed 06/01/2007

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS _________________________________________ ) JUSTINA CORCELLES HERNANDEZ, ) REV. FR. PRISCO E. ENTINES, ) FRANCISCO GUTIEREZ FERRER, ) JULIETA TABOADA ABELLA, ) MARIA LAPAY LAURENCIANO, and ) No. 06-191C WENCESLAO N. RODRIGUEZ, ) No. 06-193C ) No. 06-205C Plaintiffs, ) No. 06-434C ) No. 06-442C v. ) No. 06-449C ) THE UNITED STATES, ) ) Defendant. ) __________________________________________) DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME TO RESPOND TO COMPLAINT Defendant respectfully requests the Court to grant an enlargement of time of 13 days, to and including June 14, 2007, within which to file its response to the above-referenced complaints. The response is currently due on June 1, 2007. This is our second request for an enlargement of time, the Court having previously granted a 21-day enlargement of time for this purpose. On May 31, 2007, plaintiff's counsel, Richard Arnholt, advised counsel for defendant that plaintiffs do not oppose the motion. The six complaints allege claims against the United States Department of Veterans Affairs ("VA"), and the United States Army ("Army"). The nature and subject matter of the complaints, which were filed pro se, and concern facts and potential claims from the past 60 years ago, has resulted in the need for more time to fully respond to the complaint. Although a draft response has been prepared, defendant's counsel was advised on May 31, 2007 by counsel for one of the affected agencies that the agency needs additional time to review the draft and

Case 1:06-cv-00449-TCW

Document 25

Filed 06/01/2007

Page 2 of 2

provide its input to defendant's counsel. The requested enlargement of time should provide sufficient time for the Government to complete the necessary inter- and intra-agency review prior to filing the response with this Court. For these reasons, we respectfully request the Court grant this motion for an enlargement of time to extend the Government's deadline for filing its response until June 14, 2007.

Respectfully submitted, PETER D. KEISLER Assistant Attorney General JEANNE E. DAVIDSON Director

/s/ Donald E. Kinner DONALD E. KINNER Assistant Director

/s/ Kenneth S. Kessler KENNETH S. KESSLER Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L Street, N.W. Washington, D.C. 20530 Department of Justice Tel: (202) 307-0313 Fax: (202) 307-0313 June 1, 2007 Attorneys for Defendant 2