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

Case 1:06-cv-00113-MBH

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Filed 04/13/2006

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS OAK ENVIRONMENTAL CONSULTANTS, INC., Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) )

No. 06-113C (Judge Horn)

DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME TO RESPOND TO THE COMPLAINT Pursuant to United States Court of Federal Claims Rule 6.1, we respectfully request an enlargement of time of 65 days, from April 17, 2006, through and including June 21, 2006, to respond to the complaint. This is our first request for an enlargement Plaintiff's counsel does not oppose

of time for this purpose. this motion.

This action arises from a Navy construction contract. enlargement of time is necessary to provide the agency with

An

additional time to prepare the required litigation report, and to provide undersigned counsel of record with time needed to explore various issues, discuss the matter at length with agency personnel, prepare the Government's draft response to the complaint and submit the draft response for internal review. In addition, counsel is responsible for the following cases, among others, that will require his attention in the coming weeks: (1) Friedman v. United States, Fed. Cl. No. 05-1355C (response to complaint due April 20, 2006; (2) Stone v.

Case 1:06-cv-00113-MBH

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Department of Veterans Affairs, Fed. Cir. No. 06-7069 (Government's brief due May 12, 2006); (3) Lee v. United States, CIT No. 05-191 (initial disclosures due May 15, 2006); (4) Doe v. United States, Fed. Cl. No. 04-370C (Government's response to plaintiff's motion for leave to file amended complaint due May 18, 2006); (5) John Snow, Inc. v. United States, Fed. Cl. No. 0697C (response to complaint due June 6, 2006); and (6) China Processed Food Import & Export Co. v. United States (Government's supplemental response brief due July 19, 2006). responsible for numerous other matters as well. CONCLUSION For the foregoing reasons, defendant, the United States, respectfully requests that this Court grant the Government an enlargement of time, through and including June 21, 2006, to respond to the complaint. Counsel is

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Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director s/Steven J. Gillingham STEVEN J. GILLINGHAM Assistant Director s/Richard P. Schroeder RICHARD P. SCHROEDER Trial Attorney Commercial Litigation Branch Civil Division U.S. Department of Justice Attn: Classification Unit Eighth Floor 1100 L Street, N.W. Washington, D.C. 20530 Tele: (202) 305-7562 Attorneys for Defendant April 13, 2006

Case 1:06-cv-00113-MBH

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CERTIFICATE OF FILING I hereby certify under penalty of perjury that on this 13th day of April 2006, a copy of the foregoing "DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME TO RESPOND TO THE COMPLAINT" 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/Richard P. Schroeder