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

Case 1:06-cv-00345-EGB

Document 5

Filed 06/16/2006

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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 31 days, to and including July 28, 2006. Our response currently is due June 27, 2006. This is our first motion for additional time for this purpose. 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 the delay experienced by undersigned counsel in receiving plaintiff's complaint. Although the complaint was filed on April 28, 2006, undersigned counsel was not assigned to the case, and did not receive a copy of the complaint until May 16, 2006. In addition, undersigned counsel has been occupied with the following tasks in other matters: (1) preparation of a reply to a motion for relief from judgment in Doe v. United States, (Fed. Cl. No. 04-90) filed May 22, 2006; (2) preparation of an informal brief filed May 26, 2006 in Swindell v. Department of Veterans Affairs, (Fed. Cir. No. 06-7142); (3) preparation of a status report and class action discovery plan in Filosa, et al. v. United States, (Fed. Cl.

Case 1:06-cv-00345-EGB

Document 5

Filed 06/16/2006

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No. 04-710) filed May 31, 2006; (4) resolution of a dispute regarding a stipulation for military back pay in Strickland v. United States, (Fed. Cl. No. 03-1390) with a reply brief filed June 5, 2006; (5) preparation of a joint preliminary status report ("JPSR") filed June 8, 2006 in WTAK-2 v. United States, (Fed. Cl. No. 05-1282); (6) preparation of a JPSR filed June 8, 2006 in Toste, et al. v. United States, (Fed. Cl. No. 004-902); and (7) preparation of a cross-motion for summary judgment and accompanying filings in Bair, et al. v. United States, (Fed. Cl. No. 04-1689) due June 13 and 16, 2006. 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 unopposed motion to enlarge the deadline for our response to plaintiff's complaint by 31 days, to and including July 28, 2006. Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director /s/Franklin E. White, Jr. FRANKLIN E. WHITE, JR. Assistant Director

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Case 1:06-cv-00345-EGB

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Filed 06/16/2006

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/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 June 16, 2006 Attorneys for Defendant

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Case 1:06-cv-00345-EGB

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Filed 06/16/2006

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CERTIFICATE OF FILING I hereby certify that on June 16, 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