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

Case 1:04-cv-00633-ECH

Document 5

Filed 06/01/2004

Page 1 of 2

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

No. 04-633C (Judge Hewitt)

DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME Pursuant to Rule 6(b)(1) of the Rules of the United States Court of Federal Claims ("RCFC"), defendant, the United States, respectfully requests a 30-day enlargement of time, to and including July 8, 2004, within which to respond to plaintiff's complaint in this case. Our response is currently due on June 8, 2004. This is the Government's first request for an enlargement of time for this purpose. Counsel for plaintiff, Arthur N. Lerner, has indicated that plaintiff does not oppose this motion. The additional time requested in this motion is necessary because we have not yet received a litigation report or any documentation that may be required in order to provide a complete response to the complaint. See 28 U.S.C. § 520. It is anticipated that the agency will provide counsel with the litigation report and any supporting documents within sufficient time to prepare our response for filing on July 8, 2004. For the above reasons, defendant respectfully requests that the Court grant this unopposed motion for an enlargement of time of 30 days, to and including July 8, 2004, to respond to the complaint.

Case 1:04-cv-00633-ECH

Document 5

Filed 06/01/2004

Page 2 of 2

Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director s/ Kathryn A. Bleecker KATHRYN A. BLEECKER Assistant Director OF COUNSEL: JILL GERSTENFIELD Attorney Officer of the General Counsel Office of Personnel Management 1900 E Street, N.W. Washington, D.C. 20415 s/ Carolyn J. Craig CAROLYN J. CRAIG Trial Attorney Commercial Litigation Branch Civil Division Department of Justice 1100 L Sreet, N.W. Attn: Classification Unit, 8th floor Washington, D.C. 20530 Tele: (202) 305-7561 Fax: (202) 305-7644 e-mail: [email protected] Attorneys for Defendant

June 1, 2004

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