Free Motion for Extension of Time to File Response/Reply - District Court of Federal Claims - federal

Case 1:06-cv-00146-TCW

Document 5

Filed 04/20/2006

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS TETRA TECH EC, INC., Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 06-146C (Judge Wheeler)

DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME Pursuant to Rule 6.1 of the Rules of the Court of Federal Claims, the defendant, United States, respectfully requests that the Court enlarge by 32 days, from April 28, 2006, to and including May 30, 2006, the deadline for its response to the plaintiffs' complaint. This is the Government's first such request. Plaintiff does not oppose this motion. Undersigned counsel was not assigned to this matter until March 15, 2006. On March 16, 2006, the Department of Justice sent a letter to the relevant agency, the Army Corps of Engineers, requesting that agency counsel be appointed and that relevant information be gathered. However, agency counsel was not assigned until April 18, 2006. Undersigned Department of Justice counsel and agency counsel have begun working together on this matter. However, due the recency of her appointment to this matter, agency counsel has not been able to complete the litigation report that undersigned counsel will use to formulate the defendant's response to plaintiff's complaint. Undersigned counsel does expect that the Government will be able to prepare a complete and accurate response to plaintiff's complaint by May 30, 2006.

Case 1:06-cv-00146-TCW

Document 5

Filed 04/20/2006

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Granting this enlargement should not cause any material inconvenience, prejudice, or delay. Accordingly, we respectfully request that the Court enlarge by 32 days, from April 28, 2006, to and including May 30, 2006, the deadline for the defendant's response.

Respectfully submitted, PETER D. KEISLER. Assistant Attorney General DAVID M. COHEN Director s/ Steven J. Gillingham STEVEN J. GILLINGHAM Assistant Director s/ James D. Colt JAMES D. COLT Trial Attorney Department of Justice Civil Division Commercial Litigation Branch 1100 L. Street, NW Attn: Classification Unit 8th Floor Washington, D.C. 20530 Tel: (202) 305-7562 Fax: (202) 305-7643 April 20, 2006 Attorneys for Defendant

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Case 1:06-cv-00146-TCW

Document 5

Filed 04/20/2006

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CERTIFICATE OF SERVICE I hereby certify that on this 20th day of April, 2006, a copy of the foregoing DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME was filed electronically. I understand that notice of this filing will be sent to all parties of record by operation of the Court's electronic filing system. Parties may access this filing through the Court's system.

s/ James D. Colt

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