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

Case 1:05-cv-00297-LSM

Document 5

Filed 05/04/2005

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS STERLING, WINCHESTER & LONG, L.L.C., Plaintiff, v. THE UNITED STATES OF AMERICA, Defendant. ) ) ) ) ) ) ) ) ) )

No. 05-297C (Judge Margolis)

DEFENDANT'S UNOPPOSED REQUEST FOR AN ENLARGEMENT OF TIME Defendant respectfully requests an enlargement of time of 28 days, to and including June 7, 2005, to respond to plaintiff's complaint. Our response is currently due on May 10, 2005. This is defendant's first request for an enlargement of time for this purpose. Plaintiff's counsel has stated that plaintiff would not oppose the Government's motion. Defendant's counsel has contacted the United States Postal Service in order to obtain information about this case. She has not yet received a litigation report which is needed in order to respond to the complaint. Defendant's counsel expects to receive this information during the week of May 9-13, 2005, or May 16-20, 2005. Once defendant's counsel receives this information, she will require at least two weeks to review it and to discuss the case with agency representatives in order to prepare the Government's response to the complaint, including the possible assertion of defenses and/or counterclaims. For the foregoing reasons, we respectfully request that the Court grant our motion. Respectfully submitted, PETER D. KEISLER Assistant Attorney General

Case 1:05-cv-00297-LSM

Document 5

Filed 05/04/2005

Page 2 of 3

/s/ David M. Cohen DAVID M. COHEN Director /s/ Sheryl L. Floyd SHERYL L. FLOYD Senior Trial Counsel Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L Street, N.W. Washington, D.C. 20530 Tele: (202) 307-0282 Facsimile: (202) 514-8624 Attorneys for Defendant

OF COUNSEL: CHRISTOPHER J. BURTON United States Postal Service 475 L'Enfant Plaza, SW Washington, DC 20260-1127

MAY 4, 2005

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Case 1:05-cv-00297-LSM

Document 5

Filed 05/04/2005

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that on this 4th day of MAY, 2005, a copy of "DEFENDANT'S UNOPPOSED REQUEST FOR 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. Parties may access this filing through the Court's system.

/s/ Sheryl L. Floyd