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

Case 1:06-cv-00226-EGB

Document 6

Filed 07/20/2006

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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 60-day enlargement of time, to and including September 19, 2006, to file a response to the complaint. Our response is currently due on July 21, 2006. This

is defendant's second 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 currently conducting settlement negotiations. Counsel have

discussed how they could resolve this matter in an efficient and cost-effective manner. Counsel believe they are close to an

agreement and require additional time to collect information and evaluate proposed settlement terms. For these reasons, defendant respectfully requests that the

Case 1:06-cv-00226-EGB

Document 6

Filed 07/20/2006

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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) 305-7562 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 July 20, 2006 Attorneys for Defendant

Case 1:06-cv-00226-EGB

Document 6

Filed 07/20/2006

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CERTIFICATE OF SERVICE I hereby certify that on July 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