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

Case 1:04-cv-00718-ECH

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Filed 06/21/2004

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS CW GOVERNMENT TRAVEL, INC., Plaintiff, v. UNITED STATES, Defendant. ) ) ) ) ) No. 04-718C ) (Judge Hewitt) ) ) )

DEFENDANT'S MOTION FOR AN ENLARGEMENT OF TIME Pursuant to Rule 6(b), defendant respectfully requests an enlargement of time of 30 days, to and including July 26, 2004, within which to file a response to plaintiff's complaint. Our response is currently due for filing on June 25, 2004. Plaintiff's counsel has represented that he will oppose this request. Defendant's counsel received the agency's litigation report on June 10, 2004. The allegations raised by plaintiff are

voluminous and complex, and appear, at first blush, to raise issues concerning the Court's jurisdiction. Accordingly,

defendant's counsel needs additional time to research the issues involved in this case and determine the proper response to plaintiff's complaint. Defendant's counsel has been unable to

conduct the research and analysis necessary to respond to plaintiff's complaint in the past week, and will be unable to do so in the next week, because her time has been taken up in responding to a bid protest in Aliron v. United States, Fed. Cl. No. 04-873C; filing a cross-motion and response to plaintiff's

Case 1:04-cv-00718-ECH

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Filed 06/21/2004

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renewed motion for summary judgment in Godwin v. United States, No. 98-167C on June 11, 2004; and, preparing the Government's response to appellant's brief in Martin v. Dept. of Veterans Affairs, Fed. Cir. No. 04-3023, to be filed on June 25, 2004. Accordingly, defendant's counsel has not had the necessary time to examine plaintiff's complaint and the agency's litigation report, and prepare a response to the complaint filed in this case. Accordingly, this 30 day enlargement will permit the

Government the necessary time to become familiar with the contract at issue in this case, and make a determination as to how best respond to plaintiff's complaint. For the foregoing reasons, defendant respectfully requests the Court to grant an enlargement of time, to and including July 26, 2004, within which to respond to plaintiff's renewed motion for summary judgment. Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director s/Mark A. Melnick for James Kinsella JAMES M. KINSELLA Deputy Director

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Case 1:04-cv-00718-ECH

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Filed 06/21/2004

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s/Lisa B. Donis LISA B. DONIS 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) 305-7561 Attorneys for Defendant JUNE 21, 2004

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Case 1:04-cv-00718-ECH

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Filed 06/21/2004

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CERTIFICATE OF FILING I hereby certify that on June 21, 2004, a copy of foregoing "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. may access this filing through the Court's system. Parties

s/Lisa B. Donis LISA B. DONIS

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