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

Case 1:06-cv-00442-TCW

Document 22

Filed 05/16/2007

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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 21 days, to and including June 1, 2007, within which to file its response to the above-referenced complaints. The response is currently due on May 11, 2007. Counsel for defendant conferred with plaintiff's counsel, Richard Arnholt, on May 10, 2007, and was advised by Mr. Arnholt 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"). Although the complaints are similar in nature, they are not identical. As a result, and the nature and subject matter of the complaints, which were filed pro se, concerning claims dating back potentially 60 years, will necessitate additional time by defendant to accurately and completely sort through all of the alleged claims. 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 1, 2007.

Case 1:06-cv-00442-TCW

Document 22

Filed 05/16/2007

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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/ 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 May 10, 2007 Attorneys for Defendant

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