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

Case 1:98-cv-00720-GWM

Document 273

Filed 01/19/2005

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS PRECISION PINE & TIMBER, INC., Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 98-720C (Judge George W. Miller)

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 two-day enlargement of time, to and including Tuesday, January 25, 2005, within which to file and serve a response to the plaintiff's motion for reconsideration. The United States' response to plaintiff's motion for reconsideration is currently due on Friday, January 21, 2005. This is the United States' first request for an enlargement of time for this purpose. We have discussed this request with Richard W. Goeken, counsel for plaintiff Precision Pine & Timber, Inc. ("Precision Pine"), who has informed us that Precision Pine does not oppose this motion. On January 6, 2005, the Court directed the United States to file a response to Precision Pine's motion for reconsideration on Friday, January 21, 2005. Work upon the United States' response has proceeded diligently. However, the Government is closed due to the Presidential inauguration on January 20, 2005. Further, as a result of increased security attending the inauguration, undersigned counsel's ability to freely travel to the office is likely to be affected. This enlargement of time is sought to enable the counsel sufficient time to draft the United States' response brief and to complete the supervisory review process. The requested enlargement of time to and until Tuesday, January 25, 2005 is reasonable under the circumstances.

Case 1:98-cv-00720-GWM

Document 273

Filed 01/19/2005

Page 2 of 2

Accordingly, the United States respectfully requests that the Court grant this unopposed motion for an enlargement of time. Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director s/ Kathryn A. Bleecker KATHRYN A. BLEECKER Assistant Director s/ David A. Harrington DAVID A. HARRINGTON Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L Street, N.W. Washington, D.C. 20530 (202) 307-0277 Attorneys for Defendant January 19, 2005