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

Case 1:05-cv-00966-LAS

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Filed 11/03/2005

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS GOVERNMENT TELECOMMUNICATIONS, INC., Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) No. 05-966C ) (Senior Judge Smith) ) ) )

DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Defendant respectfully requests an enlargement of time of 21 calendar days, to and including November 28, 2005, within which to file its response to plaintiff's complaint in this case. Defendant's response currently is due to be filed on November 7, 2005. This is defendant's first request for an enlargement of Counsel for defendant has contacted

time for this purpose.

counsel for plaintiff regarding this motion; he has stated that plaintiff does not oppose this motion. The additional time is necessary because counsel for defendant has not yet received the agency's comments regarding plaintiff's complaint. We rely upon agency counsel to prepare a

litigation report concerning the case, pursuant to 28 U.S.C. § 520, so that we may properly respond to actions filed against the United States. Counsel for defendant expects to receive the Thus,

agency's litigation report within the next few weeks.

the additional time is necessary within which to review the litigation report, and prepare and file our response to plaintiff's complaint.

Case 1:05-cv-00966-LAS

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Filed 11/03/2005

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For the foregoing reason, we respectfully request that our unopposed motion for an enlargement of time be granted. Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director s/ Harold D. Lester, Jr. HAROLD D. LESTER, JR. Assistant Director s/ Lauren S. Moore LAUREN S. MOORE Attorney Commercial Litigation Branch Civil Division Department of Justice 1100 L Street, N.W. Attn: Classification Unit 8th Floor Washington, D.C. 20530 Tele: (202) 307-6288 Fax: (202) 514-8640 Attorneys for Defendant NOVEMBER 3, 2005

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Case 1:05-cv-00966-LAS

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Filed 11/03/2005

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CERTIFICATE OF FILING I hereby certify that on the 3rd day of NOVEMBER, 2005, 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. filing through the Court's system. /s/ Lauren S. Moore Parties may access this