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

Case 1:05-cv-00580-TCW

Document 6

Filed 07/21/2005

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS CITY CRESCENT LIMITED PARTNERSHIP, Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) ) )

No. 05-580 (Judge Damich)

DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME Pursuant to Rule 6(b) of the Rules of the United States Court of Federal Claims, defendant, the United States, respectfully requests a 30-day enlargement of time within which to respond to plaintiff's complaint. is currently due on July 26, 2005. The Government's response The extension would bring the This is

date for responding to the complaint to August 25, 2005.

defendant's first request for an enlargement of time for this purpose. Counsel for plaintiff indicated on July 19, 2005 that

plaintiff is not opposed to this motion. This 30-day request for enlargement is necessitated by the fact that Government counsel has not yet received from the agency the litigation report required by 28 U.S.C. § 520(b). Because

the litigation report is essential for formulating a response to this complaint, counsel for the Government will not be able to respond prior to receiving the report. The 30-day extension will

provide sufficient time for agency counsel to provide the

Case 1:05-cv-00580-TCW

Document 6

Filed 07/21/2005

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litigation report and for defendant's counsel to gather necessary information, review the litigation report, and respond to the complaint. For these reasons, defendant respectfully requests that the Court grant defendant's motion for an enlargement of time of 30 days, to and including August 25, 2005, within which to respond to plaintiff's complaint.

Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director /s/ Deborah A. Bynum DEBORAH A. BYNUM Assistant Director /s/ Michael J. Dierberg MICHAEL J. DIERBERG Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit, 8th Fl. 1100 L. St. NW Washington, DC 20530 Telephone: (202) 353-0536 Facsimile: (202) 307-0972 Attorneys for Defendant July 21, 2005