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

Case 1:01-cv-00680-GWM

Document 101

Filed 12/05/2007

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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 30 days, to and including January 22, 2008, within which to prepare and file our response to plaintiff's application for attorney fees. The Government's response is currently due on December 21, 2007. This is our first 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, among other matters, defendant's counsel is required to prepare and serve the following: (1) the Government's responses to plaintiff's interrogatories and requests for the production of documents in Cooke v. United States, Fed. Cl. No. 06-748C, by December 7, 2007; (2) the Government's initial disclosures in United States v. Tip Top Pants, Inc., CIT No. 07-00171, by December 10, 2007; and (3) the Government's responses to plaintiff's interrogatories and requests for the production of documents in Kawa v. United States, Fed. Cl. No. 06-448C, by December 21, 2007. Defendant's counsel is also required to prepare and file the Government's brief in Owens v.

Case 1:01-cv-00680-GWM

Document 101

Filed 12/05/2007

Page 2 of 3

Department of Transportation, Fed. Cir. No. 2007-3212, by December 24, 2007. In addition, defendant's counsel is required to take plaintiff's deposition in Kawa on December 7, 2007. Accordingly, we respectfully request that the Court grant defendant's unopposed motion for an enlargement of time of 30 days, to and including January 22, 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 December 5, 2007 Attorneys for Defendant

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Case 1:01-cv-00680-GWM

Document 101

Filed 12/05/2007

Page 3 of 3

CERTIFICATE OF SERVICE I certify under that on this 5th day of December, 2007, 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