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

Case 1:05-cv-01040-SGB

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Filed 03/17/2006

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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 UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Defendant respectfully requests an enlargement of time of 14 days, to and including March 31, 2006, within which to file its answer. Defendant's answer is currently due on March 17, 2006. This is defendant's fourth 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. The parties have executed a settlement agreement, which has been approved by Regal and authorized Department of Justice officials. Upon payment by the Government, the parties plan to execute a joint stipulation of dismissal. An enlargement of 14 days within which to respond to plaintiff's complaint will allow the parties time to complete this 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 DAVID M. COHEN Director

Case 1:05-cv-01040-SGB

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Filed 03/17/2006

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/s Todd M. Hughes 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 March 14, 2006 Attorneys for Defendant

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Case 1:05-cv-01040-SGB

Document 11

Filed 03/17/2006

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CERTIFICATE OF FILING I hereby certify that on March 17, 2006, a copy of the foregoing "DEFENDANT'S UNOPPOSED 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