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

Case 1:06-cv-00345-EGB

Document 6

Filed 07/28/2006

Page 1 of 3

IN THE UNITED STATES COURT OF FEDERAL CLAIMS GRACE AND NAEEM UDDIN, INC., Plaintiff, v. ) ) ) ) ) ) ) ) ) )

No. 06-345C (Judge Bruggink)

THE UNITED STATES, Defendant.

DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME Pursuant to Rule 6(b) of the Rules of the United States Court of Federal Claims, defendant, the United States, respectfully requests the Court to enlarge the deadline for its response to the complaint filed by plaintiff, Grace and Naeem Uddin, Inc., by an additional 14 days, to and including August 11, 2006. Our response currently is due July 28, 2006. This is our second motion for additional time for this purpose.1 Undersigned counsel has conferred with counsel for plaintiff and is authorized to state that plaintiff does not oppose this motion. This motion is necessary because of unanticipated delays experienced by undersigned counsel in completing defendant's response to plaintiff's complaint. Since the filing of our first motion for an enlargement on June 16, 2006, undersigned counsel has been occupied with the following tasks in other matters: (1) preparation of defendant's answer in Dalles Irrigation District v. United States, (Fed. Cl. No. 05-1042) filed on July 10, 2006; (2) preparation and filing of a joint status report regarding several FOIA requests in Wollam v. United States, (Fed. Cl. No. 02-1744) filed on July 12, 2006; (3) proceedings, including a hearing on July 13, 2006, to resolve a dispute regarding military back pay and benefits in Strickland v. United States,

1

Our first motion also was unopposed and requested 31 days.

Case 1:06-cv-00345-EGB

Document 6

Filed 07/28/2006

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(Fed. Cl. No. 03-1390); (4) preparation of settlement memoranda and a status report regarding settlement filed on July 17, 2006 in SPW v. United States, (Fed. Cl. 04-794); (5) preparation for a hearing regarding various pre-trial discovery issues in Toste, et al. v. United States, (Fed. Cl. No. 04-902) conducted on July 19, 2006; and (6) preparation of a formal appellate brief due July 28, 2006 in McClain v. Office of Personnel Management, (Fed. Cir. No. 06-3183). These commitments have prevented undersigned counsel from having sufficient time to consult with agency personnel and prepare our response to plaintiff's complaint. Accordingly, we respectfully request the Court to grant this motion to enlarge the deadline for our response to plaintiff's complaint by 14 days, to and including August 11, 2006. Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director /s/Franklin E. White, Jr. FRANKLIN E. WHITE, JR. Assistant Director /s/Gregory T. Jaeger GREGORY T. JAEGER Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L Street, N.W. Washington, D.C. 20005 (202) 353-7955 July 28, 2006 Attorneys for Defendant

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Case 1:06-cv-00345-EGB

Document 6

Filed 07/28/2006

Page 3 of 3

CERTIFICATE OF FILING I hereby certify that on July 28, 2006, a copy of the foregoing "DEFENDANT'S UNOPPOSED MOTION FOR 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. Parties may access this filing through the Court's system.

/s/Gregory T. Jaeger