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

Case 1:06-cv-00306-MCW

Document 7

Filed 09/12/2006

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS TERESA KIM LANGE, Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 06-306C (Judge Williams)

DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Defendant respectfully requests an enlargement of time of 30 calendar days, to and including October 12, 2006, within which to file its response to plaintiff's complaint in this case. Defendant's response currently is due to be filed on September 12, 2006. This is defendant's first request for an enlargement Counsel for defendant has contacted

of time for this purpose.

counsel for plaintiff regarding this motion, and he has stated that plaintiff does not oppose this motion. The additional time is necessary because counsel for defendant has not yet received the agency's comments regarding plaintiff's complaint. We rely upon agency counsel to prepare a

litigation report concerning the case, pursuant to 28 U.S.C. § 520, so that we may properly respond to actions filed against the United States. Counsel for defendant expects to receive the Thus, the

agency's litigation report within the next few weeks.

additional time is necessary within which to receive and review the litigation report, and prepare and file our response to plaintiff's complaint.

Case 1:06-cv-00306-MCW

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Filed 09/12/2006

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For the foregoing reason, we respectfully request that our unopposed motion for an enlargement of time be granted. Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director s/ Brian M. Simkin BRIAN M. SIMKIN Assistant Director s/ Lauren S. Moore LAUREN S. MOORE Attorney Commercial Litigation Branch Civil Division Department of Justice 1100 L Street, N.W. Attn: Classification Unit 8th Floor Washington, D.C. 20530 Tele: (202) 307-6288 Fax: (202) 514-8640 Attorneys for Defendant SEPTEMBER 12, 2006

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Case 1:06-cv-00306-MCW

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Filed 09/12/2006

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CERTIFICATE OF ELECTRONIC FILING I hereby certify that on the 12th day of September, 2006, a copy of the foregoing "DEFENDANT'S UNOPPOSED 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, and that the parties may access this filing through the Court's system. /s/ Lauren S. Moore