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

Case 1:04-cv-00632-LJB

Document 7

Filed 06/16/2004

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS INFORMATION SYSTEMS AND NETWORKS CORPORATION, Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) )

No. 04-632C (Judge Bush)

DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME, OUT OF TIME Defendant, the United States, respectfully requests the Court to grant an enlargement of time, out of time, of 21 days, to and including June 29, 2004, within which to file our response to the complaint. Our answer was due on June 8, 2004. This is

our first request for an enlargement of time for this purpose. Counsel for plaintiff, Information Systems And Networks, Corporation ("Info Systems"), has authorized us to state that Info Systems does not oppose this motion. Counsel has recently been required to draft two briefs pursuant to expedited briefing schedules, and in the course of these activities, he failed to recognize the filing deadline for the response to the complaint in this case. Typically, counsel

notes such deadlines on his calendar, and he does not know why he failed to do so in this case. In any event, he sincerely regrets

his oversight, and he apologizes to the Court and to Info Systems for any inconvenience that his oversight may have caused.

Case 1:04-cv-00632-LJB

Document 7

Filed 06/16/2004

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The full enlargement of time is needed to permit counsel to perform the necessary research, and to draft a response to the complaint. In addition, time is needed for review of the draft

response by the agency and by supervisors at the Department of Justice. For the reasons set forth above, we respectfully request that the Court grant our unopposed motion for an enlargement of time. Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director S/ Franklin E. White, Jr. FRANKLIN E. WHITE, JR. Assistant Director S/ James W. Poirier JAMES W. POIRIER Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor, 1100 L St, N.W Washington, D.C. 20530 Tele: 202-307-6289 Fax: 202-514-7969 June 16, 2004 Attorneys for Defendant

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Case 1:04-cv-00632-LJB

Document 7

Filed 06/16/2004

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CERTIFICATE OF FILING I hereby certify that on June 16, 2004, a copy of the foregoing "DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME, OUT 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. filing through the Court's system. S/ James W. Poirier Parties may access this