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

Case 1:05-cv-00586-MCW

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Filed 11/02/2005

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS DANKA DE PUERTO RICO, INC., Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) No. 05-586C ) (Judge Williams) ) ) )

DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Defendant respectfully requests an enlargement of time of 30 days, to and including December 2, 2005, within which to respond to plaintiff's complaint. Defendant's response to plaintiff's This is our

complaint is currently due on November 2, 2005.

third request for an enlargement of time for this purpose. Plaintiff's counsel has indicated that plaintiff does not oppose this motion. Upon receipt of the complaint, defendant's counsel promptly forwarded it to the United States Property and Fiscal Officer for review and assistance. This case involves a Puerto Rican The unusual

contractor performing a contract in Puerto Rico.

location of this case has contributed to the further extension of time that is required for defendant's counsel to gather information and points of contact for the case. In addition, during the time requested in the previous motion for enlargement, defendant's counsel was required to prepare the post trial brief in Daewoo v. United States, Case No.

Case 1:05-cv-00586-MCW

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Filed 11/02/2005

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02-1914C, which was a very time consuming process that occupied more of the enlargement than anticipated. The further enlargement is necessary to permit defendant's counsel to continue to gather the necessary information to respond to plaintiff's complaint, prepare the appropriate response, obtain supervisory review, and file it. For the foregoing reasons, we respectfully request the Court to grant our unopposed out of time motion for an enlargement of time of 30 days. Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director s/Harold D. Lester, Jr. HAROLD D. LESTER, JR. Assistant Director s/Brian S. Smith BRIAN S. SMITH Attorney Commercial Litigation Branch Civil Division Department of Justice Washington, D. C. 20530 Tele: (202) 616-0391 Fax: (202) 353-7988 Attorneys for Defendant November 2, 2005

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Case 1:05-cv-00586-MCW

Document 11

Filed 11/02/2005

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CERTIFICATE OF FILING I hereby certify that on November 2, 2005, a copy of foregoing "DEFENDANT'S UNOPPOSED MOTION FOR AN 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/Brian S. Smith

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