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

Case 1:06-cv-00116-NBF

Document 7

Filed 04/14/2006

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS CALIFORNIA OREGON BROADCASTING, INC., Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 06-116C Judge Firestone

DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME Pursuant to Rule 6(b) and 6.1 of the Rules of the United States Court of Federal Claims, defendant, the United States, respectfully requests a 35-day enlargement of time, to and including May 23, 2006, within which to file its response to the complaint. Our response is currently due on April 18, 2006. This is defendant's first request for an enlargement of time for this purpose. The plaintiff, through counsel, has been contacted by phone regarding this request and does not oppose this motion. The enlargement is requested because the Government needs additional time to further consult with the agency and prepare an appropriate response to the complaint. As a result of initial discussions between the undersigned and agency counsel, it became apparent that additional factual investigations and legal research would be required for the Government to prepare its response. The additional time is necessary for defendant's counsel to conduct this investigation and research, as well as draft an appropriate response to the complaint, incorporate comments of agency counsel, and obtain review of its response. For the foregoing reasons, defendant respectfully requests that the Court grant this unopposed motion for an enlargement of time.

Case 1:06-cv-00116-NBF

Document 7

Filed 04/14/2006

Page 2 of 2

Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director s/Mark A. Melnick MARK A. MELNICK Assistant Director OF COUNSEL: SUZANNE BOYCE CARLSON Office of the Solicitor Pacific Southwest Region 1111 Jackson Street, Suite 735 Oakland, California 94607 s/Marla T. Conneely MARLA T. CONNEELY Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L Street Washington, D.C. 20530 tel: (202) 307-1011 fax: (202) 307-0972 Attorneys for Defendant

April 14, 2006

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