Free Motion for Extension of Time to File Response/Reply - District Court of Federal Claims - federal

Case 1:02-cv-01795-JFM

Document 116

Filed 01/27/2006

Page 1 of 3

IN THE UNITED STATES COURT OF FEDERAL CLAIMS ____________________________________ ) THE SWEETWATER, A WILDERNESS ) LODGE LLC, ) ) Plaintiff, ) ) No. 02-1795C v. ) (Senior Judge Merow) ) THE UNITED STATES, ) ) Defendant. ) ____________________________________) DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME Defendant, the United States, respectfully requests an enlargement of time of two days, to and including February 1, 2006, within which the parties are to file their respective responses to each other's post-trial brief and proposed findings of fact. The parties' post-trial briefs and proposed findings of fact are currently due on January 30, 2006. This is our second request for an enlargement of time to file and serve our responses to plaintiff's posttrial brief and proposed findings of fact. Our first request sought an enlargement of one business day. Plaintiff's counsel has stated that plaintiff does not oppose this request. The requested enlargement is necessary to permit us to complete the final 65 of our responses to plaintiff's 233 proposed findings of fact and the corresponding portions of our brief in response to plaintiff's 52-page post-trial brief, and allow sufficient time for supervisory lawyers at the Department of Justice to complete their review of our responses, so that we may file thorough responses that will be of greatest assistance to the Court. For the foregoing reasons, we respectfully request that the Court grant our motion for an enlargement of time of two days, to and including February 1, 2006, for the parties to file their respective responses to each other's post-trial brief and proposed findings of fact.

Case 1:02-cv-01795-JFM

Document 116

Filed 01/27/2006

Page 2 of 3

Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director s/ Kathryn A. Bleecker KATHRYN A. BLEECKER Assistant Director s/ John H. Williamson JOHN H. WILLIAMSON Trial Attorney Commercial Litigation Branch Civil Division U.S. Department of Justice ATTN: Classification Unit 1100 L St. N.W., 8th floor Washington, D.C. 20530 Tel: (202) 307-0277 Fax: (202) 307-0972 January 27, 2006 Attorneys for Defendant

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Case 1:02-cv-01795-JFM

Document 116

Filed 01/27/2006

Page 3 of 3

CERTIFICATE OF SERVICE I certify under penalty of perjury that on this 27th day of January, 2006, a copy of the foregoing "DEFENDANT'S UNOPPOSED MOTION 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/ John H. Williamson