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

Case 1:06-cv-00150-CCM

Document 23

Filed 01/25/2007

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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 30 days, to and including March 2, 2007, within which to respond to plaintiff's motion for summary judgment. Our response is presently due on January 31, 2007. This is our first 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 requires additional time because during the last two weeks he has been preparing briefs in Louis B. Fine Family LLC v. United States Postal Service (Fed. Cir. 061529) and Trobovic v. MSPB (Fed. Cir. 06-3341), a motion for summary judgment in Childers v. United States (Fed. Cl. 06-496) and discovery responses in K-Con Building Systems v. United States (Fed. Cl. 05-914). In addition, it has taken longer than anticipated for defendant's counsel to become familiar with this case, to which he was assigned in late November 2006. For these reasons, defendant requests that the Court grant this unopposed motion for an enlargement of time.

Case 1:06-cv-00150-CCM

Document 23

Filed 01/25/2007

Page 2 of 3

Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN 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 January 25, 2007

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Case 1:06-cv-00150-CCM

Document 23

Filed 01/25/2007

Page 3 of 3

CERTIFICATE OF FILING I hereby certify that on this 25th day of January 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

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