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

Case 1:06-cv-00312-TCW

Document 5

Filed 06/16/2006

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS MULTISERVICE JOINT VENTURE LLC, ) ) Plaintiff, ) No. 06-312C ) (Judge Wheeler) v. ) ) THE UNITED STATES, ) ) Defendant. ) ) DEFENDANT'S UNOPPOSED MOTION FOR 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 a 30-day enlargement of time, to and including July 24, 2006, within which to file a response to the complaint filed by plaintiff, Multiservice Joint Venture LLC. Our response is currently due on June 23, 2006. This is our first request for an enlargement of time for this purpose. Plaintiff's counsel states that plaintiff does not oppose this request. The requested enlargement of time is necessary because undersigned counsel has not yet received a litigation report (see 28 U.S.C. § 520) from the Department of the Navy, and the Department of Justice and the Department of the Navy require additional time to analyze the issues involved and coordinate the Government's response to plaintiff's complaint. For the foregoing reasons, we respectfully request that the Court grant our unopposed motion to enlarge the time within which we may respond to the plaintiff's complaint by 30 days, to and including July 24, 2006.

Case 1:06-cv-00312-TCW

Document 5

Filed 06/16/2006

Page 2 of 2

Respectfully submitted,

PETER D. KEISLER Assistant Attorney General

DAVID M. COHEN Director s/ Kathryn A. Bleecker KATHRYN A. BLEECKER Assistant Director s/ Andrew P. Averbach ANDREW P. AVERBACH Attorney Commercial Litigation Branch Civil Division Department of Justice 1100 L Street, N.W. Attn: Classification Unit, 8th Floor Washington, DC 20530 Tel. (202) 353-0527 Fax. (202) 305-2118 June __, 2006 Attorneys for Defendant