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

Case 1:05-cv-00551-LJB

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Filed 07/14/2005

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS HM2 CORPORATION, d/b/a HM2 CONSTRUCTORS AND FABRICATORS, Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) )

No. 05-551C (Judge Bush)

DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Defendant, the United States, respectfully requests the Court to grant an enlargement of time of 14 days, to and including July 29, 2005, within which to file our response to the complaint. Our answer is due on July 15, 2005. This is our

first request for an enlargement of time for this purpose. Counsel for plaintiff, HM2 Corporation ("HM2") has authorized us to state that HM2 does not oppose this motion. Counsel for the United States has recently received a draft answer from the agency. However, time is needed for consultation

with the agency regarding the basis for various responses, for revisions to the draft, and for review of the final draft by counsel for the agency and by superiors at the Department of Justice. The full enlargement of time requested is needed. Time is In

needed for the tasks described in the previous paragraph. addition, counsel for the United States must address other pressing obligations within the next two weeks -- including

Case 1:05-cv-00551-LJB

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important and complicated matters related to our appeal in Air Force v. United Technology Corp., 05-1393 (Fed. Cir.). For the reasons set forth above, we respectfully request that the Court grant our unopposed motion for an enlargement of time. Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director S/ Kathryn A. Bleecker KATHRYN A. BLEECKER Assistant Director S/ James W. Poirier JAMES W. POIRIER Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor, 1100 L St, N.W Washington, D.C. 20530 Tele: 202-307-6289 Fax: 202-514-7969 July 14, 2005 Attorneys for Defendant

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Case 1:05-cv-00551-LJB

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Filed 07/14/2005

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CERTIFICATE OF FILING I hereby certify that on July 14, 2005, a copy of the 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. the Court's system. S/ James W. Poirier Parties may access this filing through