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

Case 1:05-cv-01232-LJB

Document 6

Filed 01/23/2006

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS BASNIGHT, DONALD J., et. al. Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 05-1232C (Judge Bush)

DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME Pursuant to Rule 6.1 of the Rules of the Court of Federal Claims, defendant, the United States, respectfully requests that the Court enlarge by 30 days, from January 23, 2006, to and including February 22, 2006, the due-date for its response to the plaintiffs' complaint. This is the Government's first such request. The plaintiffs' counsel has indicated that she does not oppose this enlargement. Agency counsel is still preparing a litigation report and compiling documents that are necessary to draft an appropriate response to the complaint. In addition, a draft response will require internal Government review. Undersigned counsel does expect that the defendant will be able to file an appropriate response to the complaint by February 22, 2006. Granting this enlargement should not cause any material inconvenience, prejudice, or delay. Accordingly, we respectfully request that the Court enlarge by 30 days, from January 23, 2006 to and including February 22, 2006, the due date for defendant's response.

Respectfully submitted, PETER D. KEISLER Assistant Attorney General

Case 1:05-cv-01232-LJB

Document 6

Filed 01/23/2006

Page 2 of 3

DAVID M. COHEN Director s/ Patricia M. McCarthy PATRICIA M. McCARTHY 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 January 23, 2006 Attorneys for Defendant

Case 1:05-cv-01232-LJB

Document 6

Filed 01/23/2006

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that on this 23rd day of January, 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