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


File Size: 25.7 kB
Pages: 2
Date: October 19, 2005
File Format: PDF
State: federal
Category: District
Author: unknown
Word Count: 382 Words, 2,444 Characters
Page Size: Letter (8 1/2" x 11")
URL

https://www.findforms.com/pdf_files/cofc/20386/9.pdf

Download Motion for Extension of Time to File Answer - District Court of Federal Claims ( 25.7 kB)


Preview Motion for Extension of Time to File Answer - District Court of Federal Claims
Case 1:05-cv-00906-RHH

Document 9

Filed 10/19/2005

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS MARIAN K. HANSSON, Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) No. 05-906C ) ) Judge Robert H. Hodges, Jr. ) )

DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Pursuant to Rule 6(b) of the Rules of this Court, defendant respectfully requests an 18day enlargement of time to and including December 2, 2005, within which to respond to plaintiff's first amended Complaint. The Government's response is currently due on October 27, 2005. This is defendant's first request for an enlargement of time for this purpose. Plaintiff's counsel has indicated that he does not oppose this motion. This enlargement motion is necessary because counsel for the United States has not obtained a litigation report from the agency. See 28 U.S.C. ยง 520. This request is also necessary because the plaintiff filed its first amended complaint on October 14, 2005, and counsel for the agency and the undersigned have not had sufficient time to review the new allegations. In addition, Government counsel must file a responsive pleading in Triton Marine v. United States, No. 05-993C (Fed. Cl.) on or before November 14, 2005. The undersigned must also file extensive documentation in CSI Aviation Services v. United States (Dept. Of Transportation, Board of Contract Appeals) no later than October 26, 2005. Accordingly, the additional time is necessary to enable Government counsel to obtain and review

Case 1:05-cv-00906-RHH

Document 9

Filed 10/19/2005

Page 2 of 2

the litigation report, analyze its supporting documentation, evaluate the complaint, confer with agency counsel, draft an appropriate response and obtain supervisory review of the response. For these reasons, defendant respectfully requests that the Court grant defendant's unopposed motion for an enlargement of time of 18 days, to and including December 2, 2005, within which to respond to plaintiffs' first amended complaint. Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director

s/ Brian M. Simkin BRIAN M. SIMKIN Assistant Director

s/ David R. Feniger DAVID R. FENIGER Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit, 8th floor 1100 L Street, N.W. Washington, D.C. 20530 Tel: (202) 307-3390 Fax: (202) 305-2118 Attorneys for Defendant October 19, 2005

-2-