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

Case 1:05-cv-00507-JFM

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS CRAIG-BUFF LIMITED PARTNERSHIP, Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 05-507C (Senior Judge Merow)

DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Defendant respectfully requests an enlargement of time of 14 days, to and including October 27, 2005, within which to file its reply brief. Defendant's reply currently is due to be filed This is defendant's first request for an Counsel for plaintiff has

October 13, 2005.

enlargement of time for this purpose.

informed us that plaintiff does not oppose our request for an enlargement of time for this purpose. Additional time is necessary to draft our reply brief. receipt of plaintiff's response to our motion for summary judgment, counsel for defendant transmitted a copy via email to agency counsel, with a request that the agency provide to us its comments to plaintiff's response. Agency counsel has begun the Upon

process of drafting the agency's comments, however, additional time is necessary for agency counsel to complete his draft. In

addition, agency counsel is in the process of gathering documents relevant to issues raised in plaintiff's response. It is

anticipated that the agency will submit to counsel of record its comments no later than October 20, 2005.

Case 1:05-cv-00507-JFM

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Once counsel of record receives the agency's comments, additional time will be necessary to review the agency's comments, along with any additional documents, and to make any changes or additions to our reply brief prior to submitting it 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/ Brian M. Simkin BRIAN M. SIMKIN Assistant Director

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OF COUNSEL: TIMOTHY TREANOR Small Business Administration s/ David B. Stinson DAVID B. STINSON Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L Street, N.W. Washington, D.C. 20530 Tele: (202) 307-0163 Fax: (202) 514-8624 Attorneys for Defendant

October 6, 2005

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CERTIFICATE OF FILING I hereby certify that on October 6, 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/ David B. Stinson DAVID B. STINSON Parties may access this filing through