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

Case 1:05-cv-01232-LJB

Document 12

Filed 02/21/2006

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS BASNIGHT, DONALD J., et. al. Plaintiffs, 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 60 days, from February 22, 2006, to and including April 24, 2006, the deadline for its response to plaintiffs' complaint. This is the Government's second such request, having previously been granted an enlargement of 30 days. Plaintiffs' counsel has indicated that she does not oppose this enlargement. This case originally consisted of five plaintiffs. However, since our last filing with this Court, plaintiffs have amended the complaint to add an additional 18 plaintiffs. Given the number of plaintiffs, more time will be needed to gather the information necessary to make an appropriate response to the plaintiffs' amended complaint. At present, undersigned counsel does expect that the defendant will be able to file an appropriate response to the complaint by April 24, 2006. Granting this enlargement should not cause any material inconvenience, prejudice, or delay. Accordingly, we respectfully request that the Court enlarge by 60 days, from February 22, 2006 to and including April 24, 2006, the due date for defendant's response.

Case 1:05-cv-01232-LJB

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Filed 02/21/2006

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Respectfully submitted, PETER D. KEISLER Assistant Attorney General

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 February 21, 2006 Attorneys for Defendant

Case 1:05-cv-01232-LJB

Document 12

Filed 02/21/2006

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CERTIFICATE OF SERVICE I hereby certify that on this 21st day of February, 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