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

Case 1:04-cv-00790-LSM

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Filed 06/21/2004

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

No. 04-790C (Judge Sypolt)

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 14-day enlargement of time, to and including July 20, 2004, to file a response to the complaint in the above-captioned matter. July 6, 2004. Our response is currently due on

This is our first request for an enlargement of Plaintiff's counsel has indicated to the

time for this purpose.

counsel for defendant that plaintiff does not oppose this request. The requested enlargement of time is necessary, in part, because defendant's counsel has not yet received a litigation report from the agency. An enlargement of 14 days will allow

agency counsel additional time to assemble and evaluate relevant records obtained from the contracting officer and allow defendant's counsel time to review the case, coordinate our response with agency counsel, and obtain necessary internal review. Moreover, defendant's counsel will be out of town from

June 30, 2004 through July 11, 2004 to attend her own wedding and

Case 1:04-cv-00790-LSM

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honeymoon. For the foregoing reasons, we respectfully request that the Court grant our motion to enlarge the time within which we may respond to the plaintiff's complaint by 14 days, to and including July 20, 2004. Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director

S/ ROBERT E. KIRSCHMAN, JR. ROBERT E. KIRSCHMAN, JR. Assistant Director S/ KELLY B. WEISS KELLY B. WEISS Trial Attorney Commercial Litigation Branch Civil Division Department of Justice 1100 L Street, N.W. Attn: Classification Unit 8th Floor Washington, DC 20530 Tel. (202) 307-1011 Fax. (202) 514-8624 June 21, 2004 Attorneys for Defendant

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Case 1:04-cv-00790-LSM

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CERTIFICATE OF FILING I hereby certify that on June 21, 2004, 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/ KELLY B. WEISS Parties may access this filing through