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

Case 1:05-cv-00912-LMB

Document 8

Filed 10/11/2005

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS AEC Services, Inc. Plaintiff, v. UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 05-912C (Judge Baskir)

DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Defendant, the United States, respectfully requests an enlargement of time of 24 days, through and including November 14, 2005, within which to file and to serve its response to the complaint. Our response is currently due on October 21, 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 request for an enlargement of time for this purpose. Agency counsel has informed counsel of record for the United States that he will not complete a litigation report until November 4, 2005. Although agency counsel has begun to investigate the allegations in the complaint, he is scheduled to conduct a trial before a board of contract appeals from October 18 through October 21, 2005. Because of the preparations necessary for trial, agency counsel cannot complete the necessary investigation before the present date for filing our response to

Case 1:05-cv-00912-LMB

Document 8

Filed 10/11/2005

Page 2 of 2

the complaint. Agency counsel represented that he 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 November 14, 2005. For the foregoing reasons, we respectfully request that this motion be granted and the time for responding to the complaint be enlarged until November 14, 2005. Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director s/ James M. Kinsella JAMES M. KINSELLA 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 Attorneys for Defendant

Of counsel: Mark LaFeir General Services Administration

October 11, 2005