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

Case 1:05-cv-01205-MMS

Document 9

Filed 03/14/2006

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS NELSON CONSTRUCTION COMPANY, AND DONALD J. NELSON, Plaintiffs, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) ) )

No. 05-1205C (Judge Margaret M. Sweeney )

DEFENDANT'S SECOND MOTION FOR ENLARGEMENT OF TIME TO RESPOND TO PLAINTIFF'S COMPLAINT Pursuant to Rule 6(b) of the Rules of the United States Court of Federal Claims, the United States respectfully requests an enlargement of time of 14 days, to and including March 31, 2006, within which to respond to plaintiff's complaint. Our response is currently due on March 17, 2006. This is our second request for an enlargement of time for this purpose. Counsel for plaintiff has indicated that he does not object to the granting of this motion. The United States requests this enlargement of time because, while the agency's litigation report has been received, copies of the key documents were only received on March 13, 2006. Additional time is needed to review the allegations contained in the complaint, to review the key pertinent documents, to perform the necessary legal research, and to prepare an appropriate response to the complaint. Accordingly, we respectfully request the Court to enlarge the time to respond to plaintiff's complaint to and including March 31, 2006. Respectfully submitted, PETER D. KEISLER Assistant Attorney General

Case 1:05-cv-01205-MMS

Document 9

Filed 03/14/2006

Page 2 of 2

DAVID M. COHEN Director

s/ Deborah A. Bynum DEBORAH A. BYNUM Assistant Director

s/ Leslie Cayer Ohta LESLIE CAYER OHTA Trial Attorney Commercial Litigation Branch Civil Division Department of Justice 1100 L Street NW Attn: Classification Unit, 8th Floor Washington, D.C. 20530 March 14, 2006 Attorneys for Defendant