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

Case 1:05-cv-00591-LMB

Document 7

Filed 07/22/2005

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS WILLIAM L. CENTERS, Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 05-591C (Judge Baskir)

DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Defendant respectfully requests an enlargement of time of 60 days, to and including September 30, 2005, within which to respond to plaintiff's complaint. Defendant's response is now due August 1, 2005, and the Court has not granted a prior enlargement for time for this purpose. Plaintiff's counsel authorizes defendant's counsel to state that plaintiff does not oppose this motion. The time requested is to obtain the relevant files in order that we may respond to the allegations in the complaint. The case arises from a 1989 loan guarantee for a mortgage. As the result of passage of time, what we believe to be relevant files have been retired to archives. The agency estimates that it will take an additional 45 days in order to obtain the relevant files. The additional time requested is for the purpose of reviewing these files in order that we may respond to the allegations and of preparing our response. For the reasons set forth above, defendant requests the Court to grant defendant an enlargement of 60 within which to respond to plaintiffs' complaint, to and including September 30, 2005.

Case 1:05-cv-00591-LMB

Document 7

Filed 07/22/2005

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Respectfully submitted. PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director

BRIAN M. SIMKIN, Assistant Director

s/John S. Groat JOHN S. GROAT Attorney Commercial Litigation Branch Civil Division Department of Justice 1100 L Street, N.W. Attn: Classification Unit 8th Floor Washington, D.C. 20530 Tele: (202) 514-4325/166-8260 Fax: (202) 514-7965 [email protected] Attorneys for Defendant July 22, 2005

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Case 1:05-cv-00591-LMB

Document 7

Filed 07/22/2005

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CERTIFICATE OF FILING

I hereby certify that on July 22, 2005, a copy of foregoing "NOTICE OF APPEARANCE 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/John S. Groat