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

Case 1:06-cv-00271-MBH

Document 6

Filed 05/09/2006

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS GLOBAL GROUP GENERAL TRADING, LTD., ) ) Plaintiff, ) ) v. ) ) THE UNITED STATES, ) ) Defendant. )

No. 06-271C (Judge Marian Blank Horn)

DEFENDANT'S UNOPPOSED MOTION FOR EXTENSION OF TIME TO ANSWER OR OTHERWISE RESPOND TO THE COMPLAINT Pursuant to Rule 6(b) of the Rules of the United States Court of Federal Claims, the United States respectfully requests an enlargement of time of 45 days, to and including July 17, 2006, within which to answer or otherwise respond to plaintiff's complaint. Our response is currently due on June 2, 2006. This is our first request for an enlargement of time for this purpose. Counsel for plaintiff has indicated that he does not object to the granting of this motion. The United States requests this enlargement of time for the following reasons. Firstly, Government counsel initially believed that the agency involved in the contract that is the subject matter of this dispute was the Army. After dealing with the Army for over three weeks, Government counsel was informed that the cognizant contracting agency is the Navy. Government counsel has not yet been able to determine the identity of agency counsel who is or will be assigned to this case. Secondly, the contract at issue was for the lease of trailers that were used by the Department of Defense in connection with the war in Iraq. This fact alone greatly complicates the Government's ability to obtain the necessary documents and to speak to the agency personnel who have knowledge relevant to this dispute. Thirdly, without access to documents and cognizant

Case 1:06-cv-00271-MBH

Document 6

Filed 05/09/2006

Page 2 of 2

personnel, the agency is not able to prepare the statutorily required litigation report; without a litigation report, Government counsel is unable to prepare appropriate and accurate responses to the allegations in plaintiff's complaint. Thus, it is clear that the agency needs additional time to review the allegations contained in the complaint, to obtain relevant documentary materials, to speak to cognizant agency personnel, to perform the necessary legal research, and to prepare the litigation report. Accordingly, we respectfully request the Court to enlarge the time to respond to plaintiff's complaint to and including July 17, 2006. Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director

/s Steven J. Gillingham STEVEN J. GILLINGHAM Assistant Director s/Leslie Cayer Ohta LESLIE CAYER OHTA Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L Street, N.W. Washington, D.C. 20530 (202) 307-0252 (202) 307-0972 (Fax) May 9, 2006 Attorneys for Defendant

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