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

Case 1:05-cv-01179-MBH

Document 5

Filed 01/05/2006

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS RITA MOHLEN, and RICHARD SKRINDE ) ) ) Plaintiffs, ) ) v. ) ) UNITED STATES OF AMERICA, ) ) Defendant. ) __________________________________________)

No. 05-1179L Hon. Marian Blank Horn

MOTION FOR ENLARGEMENT OF TIME IN WHICH TO FILE RESPONSE TO PLAINTIFFS' COMPLAINT Defendant, United States of America, hereby moves, pursuant to Rule 6.1 of the RCFC, for an enlargement of time of twenty-eight (28) days, or to and including February 3, 2006, for the filing of its response to Plaintiffs' complaint in the above captioned matter. Plaintiffs' complaint was filed on November 7, 2005, and accordingly Defendant's response thereto is currently due on January 6, 2006. No previous enlargements of time for this response have been requested. Additional time is required in order coordinate the United States' position with agency counsel at the United States Army Corps of Engineers. These efforts have been complicated by the current holiday season. Accordingly, Defendant requests this twenty-eight (28) day enlargement of time. Counsel for Defendant has conferred with Counsel for Plaintiffs who indicated that Plaintiffs do not oppose this enlargement. WHEREFORE, for the reasons set forth above, the United States respectfully moves this Court to enlarge by twenty-eight (28) days, to February 3, 2006, the United States' time to 1

Case 1:05-cv-01179-MBH

Document 5

Filed 01/05/2006

Page 2 of 2

respond to Plaintiffs' complaint in the above captioned matter.

Dated: January 5, 2006

Respectfully submitted,

SUE ELLEN WOOLDRIDGE Assistant Attorney General United States Department of Justice Environment and Natural Resources Division

s/ Mark T. Romley Mark T. Romley Trial Attorney Natural Resources Section Environment & Natural Resources Division United States Department of Justice P. O. Box 663 Washington, D.C. 20044-0663 Telephone: (202) 305-0458 Fax: (202) 305-0274 E-mail: [email protected] Attorney for Defendant United States of America

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