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

Case 1:05-cv-01121-EJD

Document 7

Filed 12/12/2005

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS

WEST COAST CONTRACTORS OF NEVADA, INC., Plaintiff, v. THE UNITED STATES, Defendant.

) ) ) ) ) No. 05-1121C ) ) (Chief Judge Damich) ) ) )

DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT Pursuant to Rule 6.1 of the Rules of the Court of Federal Claims, defendant respectfully requests an enlargement of 60 days, from December 12, 2005 until February 17, 2006, in which to file its response to the complaint. This is defendant's first request for an enlargement for this purpose. Defendant's counsel has spoken with Ross Cooper, attorney for plaintiff, who does not oppose this motion. In support of this motion, defendant states that it has not received a litigation report in this matter from the Department of the Navy. This action arises from a deemed denial of a certified claim submitted by plaintiff to the Navy. The certified claim includes 10 discrete subparts. Defendant's counsel has been informed by the Navy that it has not determined its position on any of the parts of the claim. Thus, defendant requests an enlargement of 60 days to allow the Navy to investigate plaintiff's claim and determine its position upon each part of the claim. Respectfully submitted, PETER D. KEISLER Assistant Attorney General

Case 1:05-cv-01121-EJD

Document 7

Filed 12/12/2005

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DAVID M. COHEN Director s/Brian M. Simkin BRIAN M. SIMKIN Assistant Director s/Michael N. O'Connell MICHAEL N. O'CONNELL Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 12th Floor Washington, D.C. 20530 Tele: (202) 307-0282 Attorneys for Defendant Dated: December 12, 2005

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Case 1:05-cv-01121-EJD

Document 7

Filed 12/12/2005

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CERTIFICATE OF SERVICE I hereby certify that on this 12th day of December, 2005, a copy of the foregoing notice of appearance was filed electronically. I understand that notice of this filing will be sent to all parties by operation of the Court's electronic filing system. Parties may access this filing through the Court's system. s/ Michael N. O'Connell

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