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

Case 1:05-cv-00930-FMA

Document 6

Filed 09/30/2005

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS NORTH STAR ALASKA HOUSING CORP., Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) )

No. 05-930C (Judge Allegra)

DEFENDANT'S CONSENT MOTION FOR AN EXTENSION OF TIME TO FILE ANSWER Defendant respectfully requests a 14-day enlargement of time within which to answer or otherwise respond to plaintiff's complaint. The Government's response is currently due on The enlargement would bring the date for This is the Counsel

October 24, 2005.

responding to the complaint to November 7, 2005.

defendant's first request for an enlargement of time.

for plaintiff has represented to counsel for defendant that plaintiff does not oppose this motion. This Court may enlarge the period within which to perform an act for good cause shown before the expiration of the original period. See Rule 6(b)(1) of the Rules of the United States Court Good cause exists for an enlargement because

of Federal Claims.

on October 13, 2005, counsel of record for defendant will travel to El Paso, Texas for a trial scheduled for October 17-21, 2005 in ACE Constructors, Inc. v. United States, No. 04-299C (Fed. Cl.), and will not return to his office until October 24, 2005.

Case 1:05-cv-00930-FMA

Document 6

Filed 09/30/2005

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For these reasons, the Government respectfully requests that this Court grant this unopposed motion for an enlargement of time of 14 days within which to answer or otherwise respond to plaintiff's complaint. Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director s/Donald E. Kinner DONALD E. KINNER Assistant Director

OF COUNSEL ANA V. GORDON Assistant District Counsel United States Army Corps of Engineers

s/Timothy P. McIlmail TIMOTHY P. MCILMAIL Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L Street, N.W. Washington, D.C. 20530 Telephone: (202) 514-4325 Facsimile: (202) 514-7965 Attorneys for Defendant

September 30, 2005

2

Case 1:05-cv-00930-FMA

Document 6

Filed 09/30/2005

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Certificate of Filing I hereby certify that on September 30, 2005, a copy of Defendant's Consent Motion For An Extension Of Time to File Answer 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. through the Court's system. Parties may access this filing

s/Timothy P. McIlmail