Free Motion for Extension of Time to File Response/Reply - District Court of Federal Claims - federal

Case 1:06-cv-00232-LMB

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS

SYSTEMS DEVELOPMENT CORPORATION, Plaintiff, v. THE UNITED STATES, Defendant.

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No. 06-232C (Judge Baskir)

DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME Pursuant to Rule 6(b)(1) and 6.1 of the United States Court of Federal Claims (RCFC), defendant United States respectfully requests a 14-day enlargement of time, to and including October 15, 2007, to file a reply to plaintiff's opposition to our motion for summary judgment. Our motion is currently due on October 1, 2007. No previous requests for enlargement of time have been made by the Government for this purpose. This extension is necessary because the undersigned trial attorney has been out of the office taking depositions in two other cases, Marina Waterside, LLC. v. United States, No. 06-497C, where discovery ended September 13, 2007, and Hallwood Plaza, Inc. v. United States, No. 06-589C, where discovery is scheduled to close September 30, 2007, and additional out-of-town depositions are scheduled for the week

Case 1:06-cv-00232-LMB

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of September 27, 2007. Additionally, the undersigned trial attorney is responsible for filing a statement in anticipation of mediation on September 28, 2007, in American Casualty v. United States, No. 06354C, and with preparing for trial in Bell-BCI v. United States, 03-1613C, where a 10-day trial is scheduled to begin on October 15, 2007. On September 24, 2007, counsel for defendant communicated with Howell Riggs, counsel for the plaintiff, who indicated he does not oppose this motion. Respectfully submitted, PETER D. KEISLER Assistant Attorney General JEANNE E. DAVIDSON Director

/s/ Donald E. Kinner DONALD E. KINNER Assistant Director

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/s/ Joan M. Stentiford JOAN M. STENTIFORD Trial Attorney Commercial Litigation Branch Department of Justice Attn: Classification Unit 8th Floor 1100 L Street Washington, D.C. 20530 Tele: (202) 616-0341 Fax: (202) 514-8624 September 24, 2007 Attorneys for Defendant

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CERTIFICATE OF SERVICE I hereby certify under penalty of perjury that on this 24th September, 2007, 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. Parties may access this filing through the Court's system. day of

__/s/ Joan M. Stentiford JOAN M. STENTIFORD