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

Case 1:05-cv-00927-EJD

Document 6

Filed 10/03/2005

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS VT GRIFFIN SERVICES, INC., Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) )

No. 05-927C (Chief Judge Damich)

DEFENDANT'S CONSENT MOTION FOR AN EXTENSION OF TIME TO FILE ANSWER Defendant, the United States, respectfully requests a 14-day enlargement of time within which to answer or otherwise respond to plaintiff's complaint. due on October 24, 2005. The Government's response is currently The enlargement would bring the date This is Counsel

for 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-00927-EJD

Document 6

Filed 10/03/2005

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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/Bryant G. Snee BRYANT G. SNEE Assistant Director

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 October 3, 2005 Attorneys for Defendant

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Case 1:05-cv-00927-EJD

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Filed 10/03/2005

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Certificate of Filing I hereby certify that on October 3, 2005, a copy of the 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