Free Motion for Extension of Time - 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 July 23, 2007, to file a motion for summary judgment. Our motion is currently due on July 9, 2007. No previous requests for enlargement of time have been made by the Government for this purpose. This brief extension is necessary because Government counsel is required to be out of town in the next two weeks to attend a hearing in Former Employees of Joy Technologies, Inc. v. United States Secretary of Labor, Court of International Trade No. 06-00088; and to complete discovery in Marina Waterside, Inc. v. United States, 06-232C. Additionally, Government counsel has been unable to complete the motion before this time owing

Case 1:06-cv-00232-LMB

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to an extensive document production in A & D Fire Protection, Inc. v. United States, Case No. 03-1157C, and global settlement negotiations in Swanson Group, Inc. v. United States, 05-179C, 05-170C, and 05-171, and Scott Timber Co. v. United States, 05-708C. On June 25, 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 June 28, 2007 Attorneys for Defendant

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CERTIFICATE OF SERVICE I hereby certify under penalty of perjury that on this 28th day of

June, 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.

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