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

Case 1:06-cv-00384-CCM

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Filed 07/31/2006

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS KATHLEEN M. SCHRADER, Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 06-384C (Judge Christine O.C. Miller)

DEFENDANT'S MOTION FOR AN ENLARGEMENT OF TIME Pursuant to Rule 6(b) of the Rules of the Court of Federal Claims ("RCFC"), defendant respectfully requests an enlargement of time of 60 days through and until October 2, 2006, to file its response to plaintiff's complaint. on August 1, 2006. Our response is presently due

This is our first request for an enlargement Plaintiff's counsel does not oppose

of time for this purpose.

this request for an enlargement. Although defendant twice sought to obtain a litigation report pursuant to 28 U.S.C. § 520, the affected agency had not been identified correctly. The mistake was corrected promptly

after it came to the attention of defendant's counsel, and agency counsel was identified on July 19, 2006. As a result, agency

counsel requires additional time to investigate the allegations contained within the complaint and prepare a litigation report. Upon receipt of the litigation report, defendant's counsel will require time to study the report and determine the most appropriate response to the complaint. Therefore, we

Case 1:06-cv-00384-CCM

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Filed 07/31/2006

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anticipate that an additional 60 days will be required to prepare our response. For the foregoing reasons, defendant respectfully requests that the Court enter an order enlarging the time to respond to plaintiff's complaint through and until October 2, 2006. Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director S/Bryant G. Snee for Todd M. Hughes TODD M. HUGHES Assistant Director S/Allison Kidd-Miller ALLISON KIDD-MILLER Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor, 1100 L St. Washington, D.C. 20530 Tel: (202) 307-3050 Fax: (202) 307-0972 July 31, 2006 Attorneys for Defendant

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Case 1:06-cv-00384-CCM

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Filed 07/31/2006

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CERTIFICATE OF SERVICE I certify under penalty of perjury that on this 31st day of July, 2006, a copy of the foregoing "DEFENDANT'S MOTION FOR AN 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. filing through the Court's system. Parties may access this

/s Allison Kidd-Miller

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