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

Case 1:05-cv-00547-LAS

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Filed 06/21/2005

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS GOVERNMENT TELECOMMUNICATIONS, INC., Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) No. 05-547C ) (Senior Judge Smith) ) ) )

DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Defendant respectfully requests an enlargement of time of 45 calendar days, to and including August 26, 2005, within which to file its response to plaintiff's complaint in this case. Defendant's response currently is due to be filed on July 12, 2005. This is defendant's first request for an enlargement of Counsel for defendant has contacted

time for this purpose.

counsel for plaintiff regarding this motion; he has stated that plaintiff does not oppose this motion. The additional time is necessary because counsel for defendant has not yet received the agency's comments regarding plaintiff's complaint. We rely upon agency counsel to prepare a

litigation report concerning the case, pursuant to 28 U.S.C. § 520, so that we may properly respond to actions filed against the United States. Counsel for defendant expects to receive the

agency's litigation report within the next few weeks. Additionally, undersigned counsel for defendant will be out of the office from June 27 until July 11, 2005. Thus, the

additional time is necessary within which to review the

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litigation report, and prepare and file our response to plaintiff's complaint. For the foregoing reason, we respectfully request that our unopposed motion for an enlargement of time be granted. Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director s/ Harold D. Lester, Jr. HAROLD D. LESTER, JR. Assistant Director S/ Lauren S. Moore LAUREN S. MOORE Attorney Commercial Litigation Branch Civil Division Department of Justice 1100 L Street, N.W. Attn: Classification Unit 8th Floor Washington, D.C. 20530 Tele: (202) 307-6288 Fax: (202) 514-8640 Attorneys for Defendant JUNE 21, 2005

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CERTIFICATE OF FILING I hereby certify that on the 21st day of JUNE, 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. through the Court's system. /s/ Lauren S. Moore Parties may access this filing