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

Case 1:05-cv-00472-MCW

Document 37

Filed 06/06/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS JUDITH A. MANSFIELD, Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 05-472C (Judge Mary Ellen Coster Williams)

DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME TO FILE ITS MEMORANDA OF CONTENTIONS OF FACT AND LAW Pursuant to Rule 6(1) of the Rules of the United States Court of Federal Claims ("RCFC"), the United States respectfully requests an enlargement of time of five days, to and including June 11, 2007, to file its memorandum of contentions of fact and law. This is defendant's second request for an enlargement of time for this purpose. On May 29, 2007, the Court granted the Government's oral request for a two-day enlargement until June 6, 2007.1 Government counsel has discussed this motion with plaintiff's counsel, Mr. Bruce Fredrickson, and he has informed the United States that Ms. Mansfield does not oppose this motion for enlargement. This brief enlargement of time is necessary because the Government has not received final substantive comments from the Library of Congress regarding the initial draft of the Government's pre-trial brief. The agency's substantive comments, which we expect to receive by close-of-business today, will then need to be incorporated into a draft brief that then must undergo the review process within the Department of Justice. For the foregoing reasons, defendant respectfully requests that the Court grant this

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Government counsel requested the first brief enlargement because he was out of the office from May 31, 2007 until June 4, 2007.

Case 1:05-cv-00472-MCW

Document 37

Filed 06/06/2007

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unopposed request for an enlargement of time of 5 days until June 11, 2007 in which defendant can file its memorandum of contentions of fact and law. Respectfully submitted, PETER D. KEISLER Assistant Attorney General

JEANNE E. DAVIDSON Director

s/Todd M. Hughes by Steven Gillingham TODD M. HUGHES Deputy Director

OF COUNSEL: JESSIE JAMES Associate General Counsel Library of Congress Washington, D.C. JULIA DOUDS Assistant General Counsel Library of Congress Washington, D.C. s/Douglas K. Mickle DOUGLAS K. MICKLE Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor, 1100 L Street, N.W. Washington, D.C. 20530 Tel: (202) 307-0383 Fax: (202) 353-7988 Attorneys for Defendant

June 6, 2007

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Case 1:05-cv-00472-MCW

Document 37

Filed 06/06/2007

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CERTIFICATE OF SERVICE I hereby certify under penalty of perjury that on June 6, 2007, a copy of the foregoing "DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME TO FILE ITS MEMORANDA OF CONTENTIONS OF FACT AND LAW" 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. Parties may access this filing through the Court's system.

s/Douglas K. Mickle Douglas K. Mickle