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

Case 1:04-cv-00830-LJB

Document 6

Filed 07/08/2004

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS CARPENTER CONTRACTING, INC. Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) )

No. 04-830C (Judge Lynn J. Bush)

DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Defendant respectfully requests an enlargement of time of 28 days, to and including August 9, 2004, within which to file and to serve its response to the complaint. currently due on July 12, 2004. Our response is

We notified counsel for the

plaintiff of our intent to request an enlargement of time and he informed us that the plaintiff will not oppose this, our first request for an enlargement of time for this purpose. The undersigned attorney has not yet received a litigation report from counsel for the agency, the United States Army Corps of Engineers. Apparently, the precautions surrounding the mail The

delayed the letter requesting assistance from the agency.

undersigned attorney recently identified counsel for the agency, who has represented that the agency is gathering the information necessary to allow the United States to respond to the complaint. For the foregoing reasons, we respectfully request that this motion be granted and the time for responding to the complaint be enlarged until August 9, 2004.

Case 1:04-cv-00830-LJB

Document 6

Filed 07/08/2004

Page 2 of 2

Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director s/ James M. Kinsella by B. Simkin JAMES M. KINSELLA Deputy Director s/ Christian J. Moran CHRISTIAN J. MORAN 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) 307-6299 Fax: (202) 514-7969 Attorneys for Defendant July 8, 2004