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

Case 1:02-cv-01500-GWM

Document 73

Filed 09/22/2006

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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 UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Defendant, the United States, respectfully requests that the Court grant our motion for an unopposed enlargement of time of seven days, to and including October 2, 2006, to file our response to the motion for summary judgment filed by the plaintiff, Jacobs Engineering Group, Inc. ("Jacobs"). Our brief is due on September 25, 2006. This is our fourth

request for an enlargement of time for this purpose, the Court having granted three enlargements of time of 14 days, 14 days, and 14 days, respectively. Counsel for Jacobs has

authorized us to state that Jacobs does not oppose this motion for an enlargement of time. Counsel for the United States has completed a draft brief, but initial comments from the agency have revealed a need to make certain revisions. In addition, the comments

have revealed the need to collect at least one declaration from a person outside of Washington, D.C.

Case 1:02-cv-01500-GWM

Document 73

Filed 09/22/2006

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The full enlargement of time requested is needed. is uncertain how long it will take to gather the needed

It

declaration, but it is reasonable to assume that a few days might be required. In addition, time is needed for further

review of the draft brief by agency counsel, for review by supervisors at the Department of Justice, and for further corrections to the draft brief. 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: 202-307-6289 Fax: 202-514-7969 September 21, 2006 Attorneys for Defendant

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Case 1:02-cv-01500-GWM

Document 73

Filed 09/22/2006

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CERTIFICATE OF FILING I hereby certify that on September 21, 2006, a copy of the foregoing "DEFENDANT'S UNOPPOSED 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. may access this filing through the Court's system. S/ James W. Poirier Parties