Free Motion for Extension of Time to File Answer - District Court of Federal Claims - federal

Case 1:06-cv-00695-MMS

Document 23

Filed 09/05/2007

Page 1 of 3

IN THE UNITED STATES COURT OF FEDERAL CLAIMS BRICKWOOD CONTRACTORS, INC., Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 06-695C (Chief Judge Damich)

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 October 12, 2007, within which to prepare and file our answer. The Government's response currently is due on September 12, 2007. This is our second request for an enlargement of time for this purpose. Defendant's previous counsel, Meredyth Cohen, contacted plaintiff's counsel, Scott J. Newton, and was informed that plaintiff does not object to this motion for enlargement of time. The enlargement of time requested is necessary because agency counsel requires additional time to acquire the necessary information to respond to plaintiff's complaint. Agency counsel has been out of the office since August 30, 2007 attending to a family emergency and does not expect to return to work until at least September 7, 2007. The enlargement of time is also necessary because this case has just been reassigned to the undersigned counsel, who requires additional time to familiarize himself with the case and prepare an answer. Accordingly, we respectfully request that the Court grant defendant's unopposed motion for an enlargement of time of 30 days, to and including October 12, 2007, in which to file the Government's response.

Case 1:06-cv-00695-MMS

Document 23

Filed 09/05/2007

Page 2 of 3

Respectfully Submitted, PETER D. KEISLER Assistant Attorney General JEANNE E. DAVIDSON Director /s/ DONALD E. KINNER DONALD E. KINNER Assistant Director /s/ SEAN M. DUNN SEAN M. DUNN 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) 616-0338 Fax: (202) 353-7988 September 5, 2007 Attorneys for Defendant

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Case 1:06-cv-00695-MMS

Document 23

Filed 09/05/2007

Page 3 of 3

CERTIFICATE OF SERVICE I certify under that on this 5th day of September, 2007, a copy of the foregoing "DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME" was filed electronically. In 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/ SEAN M. DUNN