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

Case 1:05-cv-00677-CCM

Document 61

Filed 01/11/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS TAMERLANE, LIMITED, et. al, Plaintiffs, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 05-677C (Judge Christine O.C. Miller)

DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME Defendant respectfully requests an enlargement of time of three business days, to and including January 16, 2008, within which to its response to the motion of plaintiffs Tamerlane Limited and Park Terrace East Limited for partial summary judgment as to liability. Our response to plaintiffs' motion is currently due on January 11, 2008. This is our first request for an enlargement of time for this purpose. Plaintiffs' counsel has authorized us to state that plaintiffs do not oppose this motion. A draft response to plaintiffs' motion has been prepared, and submitted for review within the Department of Justice. However, because Government counsel was occupied with various other litigation matters during the week of January 7, 2008, including the preparation of court filings that were due in several other cases that week, the draft response to plaintiffs' motion in this case was not completed until late in the evening of January 10, 2008. Consequently, there has not been sufficient time for review of the draft within the Department of Justice, and additional time is required for this purpose. For the foregoing reasons, we respectfully request that our motion for an enlargement of time be granted.

Case 1:05-cv-00677-CCM

Document 61

Filed 01/11/2008

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. Respectfully submitted, JEFFREY S. BUCHOLTZ Acting Assistant Attorney General

s/Jeanne E. Davidson JEANNE E. DAVIDSON Director

Filed electronically

s/Shalom Brilliant SHALOM BRILLIANT Senior Trial Counsel Commercial Litigation Branch Civil Division Department of Justice 1100 L Street, N.W. Attn: Classification Unit 8th Floor Washington, D.C. 20530 Telephone: (202) 616-8275 Facsimile: (202) 305-7643 Attorneys for Defendant

January 11, 2008

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Case 1:05-cv-00677-CCM

Document 61

Filed 01/11/2008

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CERTIFICATE OF SERVICE I hereby certify that on the 11th day of January, 2008, a copy of the foregoing "DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME" 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. Parties may access this filing through the Court's system.

s/Shalom Brilliant