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

Case 1:06-cv-00231-EJD

Document 20

Filed 10/05/2006

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS ______________________________________ ) EDWARD GRINNELL ) ) Plaintiff, ) ) v. ) 06-231 C ) (Chief Judge Damich) THE UNITED STATES, ) ) Defendant. ) ______________________________________ ) DEFENDANT'S SECOND UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Defendant respectfully requests an enlargement of time of 14 days, to and including October 24, 2006, within which to file its response to plaintiff's complaint. Defendant's response is now due to be filed on October 10, 2006. This is defendant's second 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 held preliminary discussions regarding settlement, and the Government would like to continue to explore the possibility of settling this case before we file a response to Mr. Grinnell's complaint. An enlargement of 14 days within which to respond will allow us to continue to investigate thoroughly the possibilities for settlement, 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 20

Filed 10/05/2006

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DAVID M. COHEN Director s/ Brian M. Simkin 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 October 5, 2006 Attorneys for Defendant

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Case 1:06-cv-00231-EJD

Document 20

Filed 10/05/2006

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CERTIFICATE OF FILING I hereby certify that on this 5th day of October, 2006, a copy of the foregoing "DEFENDANT'S SECOND 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