Free Motion for Extension of Time to File Response/Reply - District Court of Federal Claims - federal

Case 1:02-cv-01500-GWM

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Filed 11/03/2006

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS JACOBS ENGINEERING GROUP, INC., ) ) Plaintiff, ) ) v. ) ) THE UNITED STATES, ) ) Defendant. )

No. 02-1500C (Judge George W. Miller)

DEFENDANT'S MOTION FOR AN ENLARGEMENT OF TIME Defendant, the United States, respectfully requests that the Court grant our motion for an enlargement of time of 14 days, to and including November 27, 2006, to file our reply to the response to our cross-motion for summary judgment. Our brief is due on November 13, 2006. This is

our first request for an enlargement of time for this purpose. We made several attempts to contact counsel for

the plaintiff, Jacobs Engineering Group, Inc. ("Jacobs"), but we were unable to reach him to determine whether Jacobs opposes this motion for an enlargement of time. Jacobs filed its response on October 25, 2006. During

the week beginning October 30th, counsel for the United States has devoted considerable time to preparation of a draft reply brief. Specifically, counsel has performed

legal research, and counsel has begun to prepare the draft brief. However, counsel was unable to complete his draft

brief by November 3, 2006, and counsel will be away from

Case 1:02-cv-01500-GWM

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Washington, D.C., on long-planned annual leave from November 4, 2006 through November 12, 2006. Thus, we will be unable

to file our reply by November 13, 2006. The full enlargement of time requested is needed. is needed for legal research, and for completion of the draft brief. In addition, time is needed for review of the Time

draft brief by counsel for the agency and by supervisors at the Department of Justice. For these reasons, we respectfully request that our motion for an enlargement of time be granted. Respectfully submitted, PETER D. KEISLER Assistant Attorney General S/ David M. Cohen DAVID M. COHEN 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) 616-0856 Fax: (202) 514-7969 November 3, 2006 Attorneys for Defendant

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Case 1:02-cv-01500-GWM

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CERTIFICATE OF FILING I hereby certify that on November 3, 2006, 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. filing through the Court's system. S/ James W. Poirier Parties may access this