Case 1:06-cv-00226-EGB
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Filed 11/20/2006
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IN THE UNITED STATES COURT OF FEDERAL CLAIMS ________________________________ ) ) ) ) Plaintiff, ) ) v. ) No. 06-226C ) (Judge Bruggink) THE UNITED STATES, ) ) Defendant. ) ________________________________) AMERICAN CONTRACTORS INDEMNITY COMPANY, DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Pursuant to Rules 6(b)(1) and 6.1 of the Rules of the United States Court of Federal Claims ("RCFC"), defendant, the United States, respectfully requests a 39-day enlargement of time, to and including December 29, 2006, to file a response to the complaint. Our response is currently due on November 20, 2006.
This is defendant's fourth request for an enlargement of time for this purpose. Counsel for plaintiff has informed us that
plaintiff does not oppose our request for an enlargement of time for this purpose. We are seeking this enlargement of time because the parties are very close to a settlement agreement. Settlement
negotiations have taken some additional time in this case because plaintiff's damages continue to accrue and the parties are attempting to agree upon a final settlement amount for each of the claims presented in plaintiff's complaint. For these reasons, defendant respectfully requests that the
Case 1:06-cv-00226-EGB
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Filed 11/20/2006
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Court grant its unopposed motion for an enlargement of time to respond to plaintiff's complaint. Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director s/Steven J. Gillingham STEVEN J. GILLINGHAM Assistant Director s/Dawn S. Conrad DAWN S. CONRAD Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L St., N.W. Washington, D.C. 20530 Tel: (202) 616-2279 Fax: (202) 305-7643 OF COUNSEL: MARY F. WITHUM Trial Attorney U.S. Department of Transportation 400 7th Street, S.W. Washington, D.C. 20590 electronically filed November 20, 2006 Attorneys for Defendant
Case 1:06-cv-00226-EGB
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Filed 11/20/2006
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CERTIFICATE OF SERVICE I hereby certify that on November 20, 2006, a copy of 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. the Court's system. Parties may access this filing through
s/Dawn S. Conrad