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

Case 1:05-cv-01006-VJW

Document 6

Filed 11/09/2005

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS FOREST GLEN PROPERTIES, LLC Plaintiff, v. UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 05-1006C (Judge Wolski)

DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Defendant, the United States, respectfully requests an enlargement of time of 56 days, through and including, January 10, 2006, within which to file and to serve its response to the complaint. Our response is currently due on November 15, 2005.

We notified plaintiff's counsel of our intent to request an enlargement of time, and he informed us that plaintiff will not oppose this, our first motion for an enlargement of time for this purpose. The undersigned attorney has not yet received a litigation report from the relevant agency, the United States Department of Housing and Urban Development. Apparently, the delivery of a

request for a litigation report pursuant to 28 U.S.C. § 520 to the agency was delayed inexplicably. We anticipate that the

agency should be able to provide the relevant information to the undersigned so that the United States can file its response to the complaint on or before January 10, 2006.

Case 1:05-cv-01006-VJW

Document 6

Filed 11/09/2005

Page 2 of 2

For the foregoing reasons, we respectfully request that this motion be granted and the time for responding to the complaint be enlarged until January 10, 2006. Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director s/ Brian M. Simkin BRIAN M. SIMKIN Assistant Director s/ Christian J. Moran CHRISTIAN J. MORAN Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L Street, N.W. Washington, D.C. 20530 Tele: (202) 307-6299 Fax: (202) 514-7969 November 9, 2005 Attorneys for Defendant