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

Case 1:06-cv-00150-CCM

Document 24

Filed 02/20/2007

Page 1 of 3

IN THE UNITED STATES COURT OF FEDERAL CLAIMS VERIDYNE CORPORATION, Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) )

No. 06-150C (Judge Block)

DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Pursuant to Rules 6(b) and 6.1 of the Rules of the United States Court of Federal Claims ("RCFC"), defendant requests an enlargement of time of 21 days, to and including March 23, 2007, within which to respond to plaintiff's motion for summary judgment. Our response is presently due on March 2, 2007. This is our second request for an enlargement of time for this purpose. Plaintiff's counsel has been contacted and does not oppose this request for an enlargement of time. Defendant's counsel's first child was born on February 14, 2007, more than two and a half weeks prior to the child's due date. Counsel has scheduled two weeks paternity leave, and expects to return to the office on February 28, 2007. Defendant's counsel anticipates that an enlargement of three weeks will be necessary to prepare a response to plaintiff's motion for summary judgment and to obtain agency and internal review and approval. For the foregoing reasons, defendant requests that the Court grant this motion for an enlargement of time.

Respectfully submitted,

Case 1:06-cv-00150-CCM

Document 24

Filed 02/20/2007

Page 2 of 3

PETER D. KEISLER Assistant Attorney General JEANNE E. DAVIDSON Acting Director s/ Steven J. Gillingham STEVEN J. GILLINGHAM Assistant Director s/ Robert E. Chandler ROBERT E. CHANDLER Trial Attorney Commercial Litigation Branch Civil Division Department of Justice 1100 L St., N.W. Attn: Classification Unit 8th Floor Washington, D.C. 20530 Tel: (202) 514-4678 Attorneys for Defendant February 20, 2007

2

Case 1:06-cv-00150-CCM

Document 24

Filed 02/20/2007

Page 3 of 3

CERTIFICATE OF FILING I hereby certify that on this 20th day of February 2007, a copy of the foregoing "Unopposed Motion for Enlargment 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. Parties may access this filing through the Court's system.

s/ Robert E. Chandler

3