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

Case 1:05-cv-01040-SGB

Document 9

Filed 02/27/2006

Page 1 of 3

IN THE UNITED STATES COURT OF FEDERAL CLAIMS REGAL DECISION SYSTEMS, INC., Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 05-1040C (Judge Braden)

DEFENDANT'S THIRD MOTION FOR AN ENLARGEMENT OF TIME Defendant respectfully requests an enlargement of time of 18 days, to and including March 17, 2006, within which to file its answer. Defendant's answer is currently due on February 27, 2006. This is defendant's third request for an enlargement of time for this purpose. We have contacted opposing counsel regarding this motion, and plaintiff does not oppose our request for an enlargement of time. The Government seeks this enlargement of time to allow the parties to complete the settlement process. Following negotiations, the Government has tentatively accepted an offer of settlement from plaintiff. Plaintiff's offer, and the accompanying terms of settlement, must now be approved or disapproved by authorized Department of Justice officials. An enlargement of 18 days within which to respond to plaintiff's complaint will allow us to attempt to complete the settlement process. For these reasons, defendant respectfully requests that the Court grant its motion for an enlargement of time. Respectfully submitted, PETER D. KEISLER Assistant Attorney General

Case 1:05-cv-01040-SGB

Document 9

Filed 02/27/2006

Page 2 of 3

DAVID M. COHEN Director /s Todd M. Hughes by Patricia M. McCarthy TODD M. HUGHES Assistant Director /s Sean B. McNamara SEAN B. McNAMARA Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor, 1100 L St. Washington, D.C. 20530 Tele: (202) 305-7573 Fax: (202) 514-8624 February 27, 2006 Attorneys for Defendant

-2-

Case 1:05-cv-01040-SGB

Document 9

Filed 02/27/2006

Page 3 of 3

CERTIFICATE OF FILING I hereby certify that on February 27, 2006, a copy of the foregoing "DEFENDANT'S THIRD MOTION FOR AN ENLARGEMENT OF TIME" 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/ Sean B. McNamara SEAN B. McNAMARA