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

Case 1:06-cv-00154-NBF

Document 6

Filed 05/01/2006

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS BEALL TECHNOLOGIES, INC., Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 06-154C (Judge Nancy B. Firestone)

DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Pursuant to Rule 6(b) of the Rules of the Court of Federal Claims ("RCFC"), defendant respectfully requests an enlargement of time of 30 days through and until May 31, 2006 to file its response to plaintiff's complaint. on May 1, 2006. Our response is presently due

This is our first request for an enlargement of Defendant's counsel has discussed this

time for this purpose.

motion with opposing counsel as required by RCFC 6.1. Plaintiff's counsel does not oppose this request for an enlargement. The parties are engaged in ongoing discussions regarding plaintiff's possible voluntary dismissal or transfer of this case. Counsel for the plaintiff has represented that he intends

to file a motion to amend the complaint to name the Federal Reserve Bank of St. Louis as defendant and transfer his claims to the United States District Court for the Eastern District of Missouri.

Case 1:06-cv-00154-NBF

Document 6

Filed 05/01/2006

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For the foregoing reasons, defendant respectfully requests that the Court enter an order enlarging the time to respond to plaintiff's complaint through and until May 31, 2006. Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director s/Mark A. Melnick MARK A. MELNICK Assistant Director s/Allison Kidd-Miller ALLISON KIDD-MILLER Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor, 1100 L St. Washington, D.C. 20530 Tel: (202) 307-1011 Fax: (202) 307-0972 May 1, 2006 Attorneys for Defendant

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Case 1:06-cv-00154-NBF

Document 6

Filed 05/01/2006

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CERTIFICATE OF SERVICE I certify under penalty of perjury that on this 1st day of May, 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. may access this filing through the Court's system. Parties

s/Allison Kidd-Miller