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

Case 1:06-cv-00150-CCM

Document 10

Filed 06/30/2006

Page 1 of 2

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 ENLARGEMENT OF TIME Defendant respectfully requests an enlargement of time of 31 calendar days, to and including July 31, 2006, in which to respond to plaintiff's first amended complaint. Defendant's response is presently due June 30, 2006. This is defendant's third request for an enlargement of time. Plaintiff's counsel has informed us that plaintiff does not oppose this motion. The additional time is requested so that the Government can complete the process of securing authorization to file special pleadings and counterclaims involving fraud, which are presently being considered in this case. As the Court is aware, such pleadings require coordination with other offices in the Department of Justice and approval by the Assistant Attorney General. We have engaged in considerable consultation with the Frauds Branch of the Civil Division since the time we filed our earlier request for enlargement and are confident that little more coordination with that branch is necessary before a recommendation can be forwarded to the Assistant Attorney General for his determination. The amount of time requested in this motion should be adequate to obtain the Assistant Attorney General's decision, which will determine the appropriate Government response to the complaint. For the foregoing reasons, defendant respectfully requests that the Court grant this unopposed motion for an enlargement of time.

Case 1:06-cv-00150-CCM

Document 10

Filed 06/30/2006

Page 2 of 2

Respectfully submitted, PETER D. KEISLER Assistant Attorney General

DAVID M. COHEN Director

s/ Steven J. Gillingham STEVEN J. GILLINGHAM Assistant Director

s/ J. Reid Prouty J. REID PROUTY Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor, 1100 L Street, N.W. Washington, D.C. 20530 Tele: (202) 305-7586 Attorneys for Defendant June 30, 2006