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 09/02/2005

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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 September 16, within which to file our response to the complaint. Our answer is due on September 2, 2005. This is our

third request for an enlargement of time for this purpose, the Court having granted an enlargement of 14 days and 35 days, respectively. Counsel for plaintiff, HM2 Corporation ("HM2") has

authorized us to state that HM2 does not oppose this motion. Because of illness, counsel for the United States has not yet had an opportunity to complete necessary tasks to prepare for the filing of a response to the complaint. Counsel planned to

accomplish these things upon return from annual leave on August 22, 2005. However, counsel was ill and away from the office from

August 22, 2005 through August 31, 2005. The full enlargement of time requested is needed. Time is

needed to review the agency's draft answer, conduct research, prepare a draft response to the complaint, and submit the draft

Case 1:05-cv-00551-LJB

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Filed 09/02/2005

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response for review by the agency and by supervisors within the Department of Justice. 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 September 2, 2005 Attorneys for Defendant

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Case 1:05-cv-00551-LJB

Document 10

Filed 09/02/2005

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CERTIFICATE OF FILING I hereby certify that on September 2, 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