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

Case 1:05-cv-00271-EJD

Document 9

Filed 05/03/2005

Page 1 of 3

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

Plaintiff, v. THE UNITED STATES,

No. 05-271C (Chief Judge Damich)

Defendant.

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, defendant, the United States, respectfully requests a 31-day enlargement of time, to and including June 6, 2005, within which to file its response to the amended complaint. Our response is currently due on May 6, 2005. This is defendant's first request for an enlargement of time for this purpose. Counsel for plaintiff has informed us that plaintiff does not oppose our request for an enlargement of time for this purpose. The enlargement is requested because defendant requires additional time to investigate the new allegations set forth in the amended complaint. Plaintiff's original complaint was three pages long and consisted of 16 numbered paragraphs. Plaintiff's amended complaint, which was filed on April 21, 2005, is eight pages long and consists of 70 numbered paragraphs. Defendant's counsel and the interested agency, the Bureau of Prisons, require additional time to investigate the new allegations and prepare an answer. For these reasons, defendant respectfully requests that the Court grant its unopposed motion for an enlargement of time.

Case 1:05-cv-00271-EJD

Document 9

Filed 05/03/2005

Page 2 of 3

Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director s/Donald E. Kinner DONALD E. KINNER Assistant Director s/Roger A. Hipp ROGER A. HIPP Trial Attorney Commercial Litigation Branch Civil Division U.S. Department of Justice Attn: Classification Unit 8th Floor 1100 L Street, N.W. Washington, D.C. 20530 Tele: (202) 307-0277 Fax: (202) 307-0972 May 3, 2005 Attorneys for Defendant

Case 1:05-cv-00271-EJD

Document 9

Filed 05/03/2005

Page 3 of 3

Certificate of Filing I hereby certify that on May 3, 2005, a copy of the foregoing "Defendant's Unopposed Motion For 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/ Roger A. Hipp