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

Case 1:06-cv-00359-LMB

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS AMY B. BURKHOLDER, Plaintiff, v. UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 06-359C (Judge Baskir) (ADR Judge Horn)

DEFENDANT'S UNOPPOSED MOTIONFOR AN ENLARGEMENT OF TIME Pursuant to Rules 6(b) and 6.1 of the Rules of the United States Court of Federal Claims ("RCFC"), defendant, the United States, respectfully requests that the Court grant an enlargement of time of 45 days, to and including October 9, 2007, within which to prepare and file our motion for summary judgment. The Government's motion currently is due on August 24, 2007. This is our first request for an enlargement of time for this purpose. Defendant's counsel contacted plaintiff's counsel, Barbara Hutchinson, and was informed that plaintiff does not object to this motion for enlargement of time. The enlargement of time requested is necessary because defendant's counsel will be on medical leave from August 16, 2007 through at least August 27, 2007. Furthermore, defendant's counsel is required to, among other matters, prepare and file the following: 1) the Government's

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brief in Price v. Department of Defense, Fed. Cir. No. 2007-3183, on or before September 11, 2007; 2) the Government's answer in Brickwood Contractors, Inc. v. United States, Fed. Cl. 06-695C, on or before September 12, 2007; and 3) the Government's brief in Darnell v. Department of Veterans Affairs, Fed. Cir. No. 2007-7216, on or before September 19, 2007. Accordingly, we respectfully request that the Court grant defendant's unopposed motion for an enlargement of time of 45 days, to and including October 9, 2007, in which to file the Government's response.

Respectfully Submitted, PETER D. KEISLER Assistant Attorney General JEANNE E. DAVIDSON Director /s/ KATHRYN A. BLEECKER KATHRYN A. BLEECKER Assistant Director

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/s/ MEREDYTH D. COHEN MEREDYTH D. COHEN Trial Attorney Commercial Litigation Branch Civil Division Department of Justice 1100 L Street, N.W. Attn: Classification Unit 8th Floor Washington, D.C. 20530 Tel: (202) 353-7978 Fax: (202) 514-8624 August 14, 2007 Attorneys for Defendant

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CERTIFICATE OF SERVICE I certify under that on this 14th day of August, 2007, a copy of the foregoing "DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME" was filed electronically. In understand that notice of this filing will be sent to all parties by operation of the Court's electronic filing system. Parties may access this filing through the Court's system.

/s/ MEREDYTH D. COHEN