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

Case 1:06-cv-00157-FMA

Document 6

Filed 04/27/2006

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS YATES INTERNATIONAL, LLC, Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 06-157C (Judge Allegra)

DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Defendant respectfully requests an enlargement of time of 45 calendar days, to and including June 15, 2006, within which to file its response to plaintiff's complaint in this case. Defendant's response currently is due to be filed on May 1, 2006. This is defendant's first request for an enlargement of time for this purpose. Counsel for defendant has contacted counsel for

plaintiff regarding this motion, and he has stated that plaintiff does not oppose this motion. The additional time is necessary because counsel for defendant has not yet received the agency's comments regarding plaintiff's complaint. We rely upon agency counsel to prepare a

litigation report concerning the case, pursuant to 28 U.S.C. § 520, so that we may properly respond to actions filed against the United States. Counsel for defendant expects to receive the Thus, the

agency's litigation report within the next few weeks.

additional time is necessary within which to receive and review the litigation report, and prepare and file our response to plaintiff's complaint.

Case 1:06-cv-00157-FMA

Document 6

Filed 04/27/2006

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For the foregoing reason, we respectfully request that our unopposed motion for an enlargement of time be granted. Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director s/ Brian M. Simkin BRIAN M. SIMKIN Assistant Director s/ Lauren S. Moore LAUREN S. MOORE Attorney Commercial Litigation Branch Civil Division Department of Justice 1100 L Street, N.W. Attn: Classification Unit 8th Floor Washington, D.C. 20530 Tele: (202) 307-6288 Fax: (202) 514-8640 Attorneys for Defendant APRIL 27, 2006

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Case 1:06-cv-00157-FMA

Document 6

Filed 04/27/2006

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CERTIFICATE OF FILING I hereby certify that on the 27th day of April, 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, and that the parties may access this filing through the Court's system. /s/ Lauren S. Moore