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

Case 1:06-cv-00382-LB

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Filed 10/06/2006

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS ANNETTE BUEHLER, Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 06-382 (Judge Block)

DEFENDANT'S MOTION FOR ENLARGEMENT OF TIME Pursuant to Rule 6(b)(1) of the Rules of the United States Court of Federal Claims ("RCFC"), defendant, the United States, respectfully requests a 50-day enlargement of time, through and including November 29, 2006, within which to file its response to the complaint. 2006. Our response is currently due on October 10,

This is defendant's first request for an enlargement of The undersigned has contacted counsel for

time for this purpose.

plaintiff, who has not yet responded with Ms. Buehler's position. The enlargement is requested because the undersigned counsel of record for defendant has not received a complete litigation report from the interested agency, the United States Postal Service ("USPS"), as required by 28 U.S.C. § 520. On October 4,

2006, agency counsel provided a partial litigation report and stated that USPS still possesses more documents that it must provide to us and those documents will be provided to the undersigned as soon as possible. The additional time is

necessary to allow sufficient time for agency counsel to complete

Case 1:06-cv-00382-LB

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the litigation report and for counsel to review the litigation report, with all the necessary attachments, and prepare the Government's response to the complaint. For these reasons, we respectfully request that the Court grant this motion for an enlargement of time. Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director

s/ Todd M. Hughes TODD M. HUGHES Assistant Director

s/ Claudia Burke CLAUDIA BURKE Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L Street Washington, D.C. 20530 tel: (202) 353-9063 fax: (202) 307-0972 October 6, 2006 Attorneys for Defendant

Case 1:06-cv-00382-LB

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CERTIFICATE OF SERVICE I hereby certify under penalty of perjury that on this 6th day of October, 2006, a copy of the foregoing notice of appearance, 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. I have also placed this

"Notice of Appearance" in the mail (first class, postage prepaid) addressed to:

Christine M. Weaver Law Office of Christine M. Weaver, P.S. 9011 E. Valleyway Ave. Spokane Valley, WA 99212

s/ Claudia Burke