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

Case 1:06-cv-00231-EJD

Document 22

Filed 11/07/2006

Page 1 of 3

IN THE UNITED STATES COURT OF FEDERAL CLAIMS ______________________________________ ) EDWARD GRINNELL ) ) Plaintiff, ) ) v. ) 06-231 C ) (Chief Judge Damich) THE UNITED STATES, ) ) Defendant. ) ______________________________________ ) DEFENDANT'S FOURTH UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Defendant respectfully requests an enlargement of time of 14 days, to and including November 21, 2006, within which to file its response to plaintiff's complaint. Defendant's response is now due to be filed on November 7, 2006. This is defendant's fourth request for an enlargement of time for this purpose. Defendant has contacted plaintiff's counsel, who has indicated that plaintiff does not oppose this request. The Government seeks this enlargement because the parties have reached an agreement to settle this case, but require more time to draft a settlement agreement, which will potentially result in the voluntary dismissal of this matter. An enlargement of 14 days within which to respond will allow us to complete the settlement process, or, if need be, prepare a response to Mr. Grinnell's complaint. For the foregoing reasons, we respectfully request that our motion be granted. Respectfully submitted, PETER D. KEISLER Assistant Attorney General

Case 1:06-cv-00231-EJD

Document 22

Filed 11/07/2006

Page 2 of 3

DAVID M. COHEN Director s/ Brian M. Simkin by Todd M. Hughes BRIAN M. SIMKIN Assistant Director s/ Sean B. McNamara SEAN B. McNAMARA Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L Street, NW Washington, D.C. 20530 Tel: (202) 305-7573 Fax: (202) 514-8624 November 7, 2006 Attorneys for Defendant

2

Case 1:06-cv-00231-EJD

Document 22

Filed 11/07/2006

Page 3 of 3

CERTIFICATE OF FILING I hereby certify that on this 7th day of November, 2006, a copy of the foregoing "DEFENDANT'S FOURTH 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. The parties may access this filing through the Court's system.

s/ Sean B. McNamara