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

Case 1:01-cv-00680-GWM

Document 103

Filed 01/14/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS J.G.B. ENTERPRISES, INC., Plaintiff, v. UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 01-680C (Judge George W. Miller)

DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Pursuant to Rules 6(b) and 6.1 of the Rules of the United States Court of Federal Claims ("RCFC"), defendant, the United States, respectfully requests that the Court grant an enlargement of time of seven days, to and including January 29, 2008, within which to prepare and file our response to plaintiff's application for attorney fees. The Government's response is currently due on January 22, 2008. This is our second request for an enlargement of time for this purpose. Defendant's counsel contacted plaintiff's counsel, Joseph A. Camardo, Jr., and was informed that plaintiff does not object to this motion for enlargement of time. The enlargement of time requested is necessary because defendant's counsel was required to prepare for and defend two depositions in Kawa v. United States, Fed. Cl. No. 06448C, held on January 8, 2008. Among other matters, defendant's counsel is required to prepare and file the parties' status report in Frank v. United States, Fed. Cl. No. 06-73C, by January 18, 2008, and the Government's response to plaintiff's complaint in Panam International Market v. United States, Fed. Cl. No. 07-808C, by January 22, 2008. Defendant's counsel is also required to prepare and serve the Government's responses to plaintiff's interrogatories, request for the production of documents, and requests for admission in Cooke v. United States, Fed. Cl. No. 06-

Case 1:01-cv-00680-GWM

Document 103

Filed 01/14/2008

Page 2 of 3

748C, by February 8, 2008. Finally, the enlargement of time is also necessary because of the large number of issues raised by plaintiff's application for attorney fees. Accordingly, we respectfully request that the Court grant defendant's unopposed motion for an enlargement of time of seven days, to and including January 29, 2008, in which to file the Government's response. Respectfully Submitted, JEFFREY S. BUCHOLTZ Acting Assistant Attorney General JEANNE E. DAVIDSON Director

/s/ FRANKLIN E. WHITE, JR. FRANKLIN E. WHITE, JR. Assistant Director

/s/ MEREDYTH D. COHEN MEREDYTH D. COHEN Trial Attorney Commercial Litigation Branch Civil Division Department of Justice 1100 L Street, N.W. Attn: Classification Unit 8th Floor Washington, D.C. 20530 Tel: (202) 353-7978 Fax: (202) 514-8624 January 14, 2008 Attorneys for Defendant

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Case 1:01-cv-00680-GWM

Document 103

Filed 01/14/2008

Page 3 of 3

CERTIFICATE OF SERVICE I certify under that on this 14th day of January, 2008, 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. Parties may access this filing through the Court's system.

/s/ MEREDYTH D. COHEN