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

Case 1:05-cv-00370-CFL

Document 6

Filed 06/09/2005

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS ADRIAN RODRIGUEZ and ALI JAZMIN RODRIGUEZ, Plaintiffs, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) )

No. 05-370C (Judge Lettow)

DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Pursuant to Rule 6.1 of the Rules of the United States Court of Federal Claims ("RCFC"), defendant, the United States, respectfully requests a 45-day enlargement of time, to and including July 29, 2005, within which to file a response to the complaint filed by plaintiffs, Adrian Rodriguez and Ali Jazmin Rodriguez. Our response is currently due on June 14, 2005. This

is our first request for an enlargement of time for this purpose. Counsel for plaintiffs has represented that she does not oppose this request. The requested enlargement of time is necessary because counsel for the United States has not yet received copies of documents necessary to formulate our response to plaintiffs' complaint. We anticipate receiving these materials within

sufficient time to prepare our response by or before the date requested in this motion. For the foregoing reasons, we respectfully request that the Court grant our unopposed motion to enlarge the time within which we may respond to the plaintiff's complaint by 45 days, to and including July 29, 2005.

Case 1:05-cv-00370-CFL

Document 6

Filed 06/09/2005

Page 2 of 2

Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director /s/Kathryn A. Bleecker KATHYRN A. BLEECKER Assistant Director /s/Andrew P. Averbach ANDREW P. AVERBACH Attorney Commercial Litigation Branch Civil Division Department of Justice 1100 L Street, N.W. Attn: Classification Unit 8th Floor Washington, DC 20530 Tel. (202) 353-0527 Fax. (202) 305-2118 June 9, 2005 Attorneys for Defendant

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