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

Case 1:06-cv-00288-CCM

Document 5

Filed 07/13/2006

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UNITED STATES COURT OF FEDERAL CLAIMS

PEOPLE OF BIKINI, BY AND THROUGH THE KILI/BIKINI/EJIT LOCAL GOVERNMENT COUNCIL, Plaintiffs, v. THE UNITED STATES, Defendant.

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No. 06-288C (Judge Block)

DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME Pursuant to Rule 6(b) of the Rules of the Court of Federal Claims ("RCFC"), defendant, the United States, respectfully requests an enlargement of time of 60 days, to and including September 15, 2006, within which to file a response to plaintiffs' complaint. Our response currently is due on July 17, 2006. We have been advised by plaintiffs' counsel that plaintiffs intend to file an amended complaint on or about July 14, 2006. Accordingly, pursuant to RCFC 15(b), our response to the amended complaint would be due 10 days after service.1 Plaintiffs' counsel does not oppose this request. The original complaint contains 110 number paragraphs, is 31 pages long, and includes several attachments - all involving matters that occurred beginning as early as 1946. We understand that the amended complaint will contain additional counts not included in the original complaint. Thus, defendant requires additional time in order to obtain and review the amended complaint, to discuss it with the several Government agencies potentially involved in this

If the amended complaint is filed on July 14, our response would be on July 24, 2006, and our enlargement would be for 53 days.

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Case 1:06-cv-00288-CCM

Document 5

Filed 07/13/2006

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litigation, and to develop an appropriate response. Accordingly, we respectfully request that the Court grant this unopposed motion for enlargement until September 15, 2006, to respond to the complaint.

Respectfully submitted, PETER D. KEISLER Assistant Attorney General s/ David M. Cohen DAVID M. COHEN Director s/ Kathryn A. Bleecker KATHRYN A. BLEECKER Assistant Director U.S. Department of Justice Civil Division Commercial Litigation Branch 1100 L Street, N.W., 8th Floor Washington, D.C. 20530 Tele: (202) 307-6288 Fax: (202) 514-8640 E-mail: [email protected] July 13, 2006 Attorneys for Defendant

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Case 1:06-cv-00288-CCM

Document 5

Filed 07/13/2006

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Certificate of Filing I hereby certify that on July 13, 2006, a copy of 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/ Kathryn A. Bleecker

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