Free Motion to Amend Schedule - District Court of Federal Claims - federal

Case 1:05-cv-00746-SGB

Document 14

Filed 04/13/2006

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS ENVIRONMENTAL TECTONICS CORPORATION, Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) )

No. 05-746C (Judge Susan G. Braden)

DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME TO FILE DISPOSITIVE MOTIONS Pursuant to Rule 6(b) of the Rules of the United States Court of Federal Claims, the United States respectfully requests an enlargement of time of 14 days, to and including April 28, 2006, within which to file a motion to dismiss. Our motion is currently due on April 14, 2006. This is our first request for an enlargement of time for this purpose. Counsel for both parties have discussed this motion, and plaintiff's counsel has indicated that there is no objection to the granting of this motion. The United States requests this enlargement of time because counsel for plaintiff has indicated that he may amend the complaint to withdraw the claims for attorneys fees and the return of liquidated damages, two claims that will be the subject of our motion to dismiss. In addition, counsel for the parties have discussed the merits of plaintiff's' claim for "interest" or financing costs. Additional time is needed to further research the merits of this claim. Accordingly, we respectfully request the Court to enlarge the time to respond to plaintiff's

Case 1:05-cv-00746-SGB

Document 14

Filed 04/13/2006

Page 2 of 2

complaint to and including April 28, 2006. Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director s/ Franklin E. White, Jr. FRANKLIN E. WHITE, JR. Assistant Director s/ Leslie Cayer Ohta LESLIE CAYER OHTA Trial Attorney Commercial Litigation Branch Civil Division Department of Justice 1100 L Street NW Attn: Classification Unit 8th Floor Washington, D.C. 20530 202-307-0252 202-307-0972 (Fax) April 13, 2006 Attorneys for Defendant