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

Case 1:06-cv-00401-NBF

Document 6

Filed 07/14/2006

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS ) ) Plaintiff, ) ) v. ) ) UNITED STATES OF AMERICA, ) ) Defendant. ) __________________________________________) JILLINA MANION,

No. 06-401L Hon. Nancy B. Firestone

MOTION FOR ENLARGEMENT OF TIME IN WHICH TO FILE A RESPONSE TO PLAINTIFF'S COMPLAINT Defendant, United States of America, hereby moves, pursuant to Rule 6.1 of the Rules of the Court of Federal Claims ("RCFC"), for an enlargement of time of thirty (30) days, or to and including August 16, 2006, for the filing of its response to Plaintiff's Complaint in the above captioned matter. Plaintiff's Complaint was filed on May 18, 2006. Accordingly, Defendant's response is currently due on July 17, 2006. There have not been any previous requests for enlargement in this matter. The additional time is required in order to internally coordinate the United States' position in response to Plaintiff's Complaint. Counsel for Defendant has conferred with Counsel for Plaintiff who indicates that Plaintiff does not oppose this enlargement. WHEREFORE, for the reasons set forth above, the United States respectfully moves this Court to enlarge by thirty (30) days, or to and including August 16, 2006, the United States' time to respond to Plaintiff's Complaint in the above captioned matter.

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Case 1:06-cv-00401-NBF

Document 6

Filed 07/14/2006

Page 2 of 2

Dated: July 14, 2006. Respectfully submitted,

SUE ELLEN WOOLDRIDGE Assistant Attorney General United States Department of Justice Environment and Natural Resources Division

s/ Mark T. Romley Mark T. Romley Trial Attorney Natural Resources Section Environment & Natural Resources Division United States Department of Justice P. O. Box 663 Washington, D.C. 20044-0663 Telephone: (202) 305-0458 Fax: (202) 305-0274 E-mail: [email protected] Attorney for Defendant

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