Free Motion for Extension of Time to File Response/Reply - District Court of Federal Claims - federal

Case 1:05-cv-00559-CCM

Document 13

Filed 11/30/2005

Page 1 of 3

IN THE UNITED STATES COURT OF FEDERAL CLAIMS PURE POWER, INC. Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 05-559C (Judge C. Miller)

DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Defendant respectfully requests an enlargement of time of 14 days, to and including December 19, 2005, within which to file its reply brief. Defendant's reply brief currently is due to be This is defendant's first request for an Counsel for plaintiff has

filed December 5, 2005.

enlargement of time for this purpose.

informed us that plaintiff does not oppose our request for an enlargement of time for this purpose. Counsel for defendant is in the process of completing a draft of the Government's reply brief. Counsel for defendant has

requested additional information from agency counsel regarding an allegation contained in plaintiff's response to our motion to dismiss. Agency counsel is in the process of locating that

additional information and contacting other agency employees regarding the request for information. Additional time is

necessary before agency counsel will be in a position to provide the information to counsel for defendant. Once the additional information is provided to counsel for defendant, additional time is necessary for defendant's counsel

Case 1:05-cv-00559-CCM

Document 13

Filed 11/30/2005

Page 2 of 3

to review the information, incorporate it into the Government's draft reply brief, and submit the draft reply brief for review by Department of Justice officials. In these circumstances, the requested enlargement of time is reasonable, and is necessary to allow sufficient time for counsel of record to prepare a thorough, responsive reply brief that will be of greatest benefit to the Court in resolving this matter. For these reasons, defendant respectfully requests that the Court grant its unopposed motion for an enlargement of time. Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director s/ Bryant G. Snee BRYANT G. SNEE Assistant Director s/ David B. Stinson DAVID B. STINSON Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor, 1100 L St. Washington, D.C. 20530 Tele: (202) 307-0163 Fax: (202) 514-8624 Attorneys for Defendant

CHRISTOPHER J. BURTON United States Postal Service Washington, D.C.

NOVEMBER 30, 2005

-2-

Case 1:05-cv-00559-CCM

Document 13

Filed 11/30/2005

Page 3 of 3

CERTIFICATE OF FILING I hereby certify that on November 30, 2005, 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. the Court's system. s/ David B. Stinson DAVID B. STINSON Parties may access this filing through