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

Case 1:06-cv-00306-MCW

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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 MOTION FOR AN ENLARGEMENT OF TIME, UPON BEHALF OF BOTH PARTIES Defendant, upon behalf of both parties, respectfully requests an enlargement of time of 11 calendar days, to and including February 12, 2007, within which to submit the initial disclosures in this case. The parties' initial disclosures

currently are due to be submitted to each other on February 1, 2007. This is either party's first request for an enlargement of Counsel for defendant has contacted

time for this purpose.

counsel for plaintiff regarding this motion, and he has stated that plaintiff concurs in this motion. The additional time is necessary because counsel for the parties have not yet completed their initial disclosures. Although undersigned counsel for defendant has begun preparation of the Government's initial disclosures, she has not yet completed it. Specifically, in the past few weeks, counsel for

defendant has been responsible for the following: preparation for and participation in oral argument in Brent v. Department of Justice, No. 2006-3153 (Fed. Cir.); preparation and submission of defendant's initial disclosures in Yates International v. United

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States, No. 06-157C (Fed. Cl.); preparation of the Government's answer in Yates International v. United States, No. 06-833C (Fed. Cl.); and preparation for and participation in settlement discussions in Government Telecommunications, Inc. v. United States, No. 05-463 (Fed. Cl.). Additionally, counsel for

defendant was out of the office on leave from January 24-29, 2007. Thus, the additional time is necessary within which to

prepare and submit the Government's initial disclosures to plaintiff. Counsel expects that an enlargement of time of 11

calendar days will be sufficient for this purpose. For the foregoing reasons, we respectfully request that our motion for an enlargement of time, upon behalf of both parties, be granted.

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Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director s/ Steven J. Gillingham STEVEN J. GILLINGHAM 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) 616-0333 Fax: (202) 514-8640 Attorneys for Defendant FEBRUARY 1, 2007

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CERTIFICATE OF ELECTRONIC FILING I hereby certify that on the 1st day of February, 2007, a copy of the foregoing "DEFENDANT'S MOTION FOR AN ENLARGEMENT OF TIME, UPON BEHALF OF BOTH PARTIES" 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

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