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

Case 1:05-cv-01185-MCW

Document 8

Filed 02/07/2006

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS GARY NOLAN and, RICARDO SERRANO, Plaintiffs, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) )

No. 05-1185C (Judge Williams)

DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME Pursuant to Rule 6(b)(1) of the Rules of the United States Court of Federal Claims ("RCFC"), defendant, the United States, respectfully requests a 30 day enlargement of time, to and including March 10, 2006, within which to file a response to the complaint. The response to the complaint is currently due on February 8, 2006. This is defendant's second request for enlargement of time for this purpose. Plaintiff's counsel has represented that he does not oppose this motion. The enlargement is requested because the undersigned counsel of record for defendant received a litigation report from the Department of Homeland Security on February 6, 2006. Based upon information in the litigation report, the parties would like to discuss the possibility of mutually resolving this matter without the need for further litigation. For the foregoing reason, defendant respectfully requests that the Court grant this motion for an enlargement of time of 30 days, to and including March 10, 2006, within which to file a response to the complaint.

Case 1:05-cv-01185-MCW

Document 8

Filed 02/07/2006

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Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director

s/ Todd M. Hughes TODD M. HUGHES Associate Director

s/ Nancy M. Kim NANCY M. KIM Trial Attorney Commercial Litigation Branch Civil Division U.S. Department of Justice Attn: Classification Unit, 8th Floor 1100 L Street, N.W. Washington, D.C. 20530 Tel: (202) 353-0546 Fax: (202) 514-8640 Attorneys for Defendant February 7, 2006