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

Case 1:05-cv-01205-MMS

Document 7

Filed 01/13/2006

Page 1 of 2

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

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

DEFENDANT'S UNOPPOSED 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 59 days, to and including March 17, 2006, within which to respond to plaintiff's complaint. Our response is currently due on January 17, 2006. This is our first request for an enlargement of time for this purpose. Counsel for plaintiff has not indicated that he does not object to the granting of this motion. The United States requests this enlargement of time because the agency's litigation report has not yet been received. The agency needs additional time review the allegations contained in the complaint, to perform the necessary legal research, and to prepare the litigation report. Accordingly, we respectfully request the Court to enlarge the time to respond to plaintiff's complaint to and including March 17, 2006. Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director

Case 1:05-cv-01205-MMS

Document 7

Filed 01/13/2006

Page 2 of 2

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 January 13, 2006 Attorneys for Defendant