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

Case 1:04-cv-00711-CCM

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Filed 06/07/2004

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS DAFNA CONSTRUCTION CO., LTD., Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 04-711C (Judge C. Miller)

DEFENDANT'S 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 45-day enlargement of time, to and including August 5, 2004, to file a response to the complaint in the above-captioned matter. June 21, 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 a request for a 30-day enlargement, but does oppose a request for a 45-day enlargement. The requested enlargement of time is necessary because defendant's counsel has not yet received a litigation report from the agency. An enlargement of 45 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. For the foregoing reasons, we respectfully request that the

Case 1:04-cv-00711-CCM

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Filed 06/07/2004

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Court grant our motion to enlarge the time within which we may respond to the plaintiff's complaint by 45 days, to and including August 5, 2004. Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director

S/ KATHRYN A. BLEECKER KATHRYN A. BLEECKER 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 7, 2004 Attorneys for Defendant

2

Case 1:04-cv-00711-CCM

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Filed 06/07/2004

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CERTIFICATE OF FILING I hereby certify that on June 7, 2004, a copy of the foregoing "DEFENDANT'S 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