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

Case 1:04-cv-00481-GWM

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Filed 07/23/2004

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

No. 04-481C (Judge G. Miller)

DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Defendant respectfully requests an enlargement of time of seven days, to and including July 30, 2004, within which to file its response to plaintiff's complaint. Defendant's response This is defendant's

currently is due to be filed July 23, 2004.

second request for an enlargement of time for this purpose. Defendant previously requested one enlargement of time of 60 days for this purpose. Counsel for plaintiff has informed us that

plaintiff does not oppose our request for an additional enlargement of time for this purpose. Counsel for defendant has completed a draft response to plaintiff's complaint. However, an issue not previously apparent

to counsel has arisen which requires additional consideration and resolution prior to completion of our response. Counsel for

defendant has requested that agency counsel provide additional information regarding the outstanding issue to defendant within the next several days. Once counsel for defendant receives the

additional information from agency counsel, additional time will be necessary to review the agency's information and to make any

Case 1:04-cv-00481-GWM

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changes or additions to our response prior to submitting it for review by Department of Justice officials. For these reasons, defendant respectfully requests that the Court grant its unopposed motion for an enlargement of time. Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director s/ Mark A. Melnick MARK A. MELNICK Assistant Director s/ David B. Stinson DAVID B. STINSON Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor, 1100 L St. Washington, D.C. 20530 Tele: (202) 307-0290 Fax: (202) 514-8624 Attorneys for Defendant

OF COUNSEL: GREGORY T. ALLEN Trial Attorney Defense Contract Management Agency Manassas, Virginia

July 23, 2004

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CERTIFICATE OF FILING I hereby certify that on July 23, 2004, 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. the Court's system. Parties may access this filing through

s/ David B. Stinson DAVID B. STINSON