Case 1:06-cv-00226-EGB
Document 5
Filed 05/17/2006
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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 July 21, 2006, to file a response to the complaint. Our response is currently due on May 22, 2006. This is
defendant's first 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. Defendant is seeking this enlargement in order to facilitate a potential settlement of this action. The parties require
additional time to conduct settlement negotiations, collect information and evaluate proposed settlement terms. For these reasons, defendant respectfully requests that the Court grant its unopposed motion for an enlargement of time to
Case 1:06-cv-00226-EGB
Document 5
Filed 05/17/2006
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respond to plaintiff's complaint.
Respectfully submitted,
PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director
s/Kathryn A. Bleecker KATHRYN A. BLEECKER 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 May 17, 2006
Attorneys for Defendant
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Case 1:06-cv-00226-EGB
Document 5
Filed 05/17/2006
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CERTIFICATE OF SERVICE I hereby certify that on May 17, 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