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

Case 1:04-cv-01470-LJB

Document 6

Filed 11/04/2004

Page 1 of 3

IN THE UNITED STATES COURT OF FEDERAL CLAIMS HEUBECK SPRINKLER INSPECTION CO., INC. v. Plaintiff, ) ) ) ) ) ) ) ) )

No. 04-1470C (Judge Bush)

THE UNITED STATES, Defendant.

DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME Pursuant to Rule 6(b)(1) and 6.1 of the United States Court of Federal Claims (RCFC), defendant United States respectfully requests a thirty (30) day enlargement of time, to and including December 15, 2004, to file a response to the complaint. response is currently due on November 15, 2004. This is Our

defendant's first request for an enlargement for this purpose. Michael Moran, counsel for plaintiff, was contacted and does not oppose this motion. Upon being assigned responsibility for this matter, defendant's counsel promptly forwarded a copy of the complaint to the agency. Defendant's counsel was first able to speak with the The agency will be

assigned agency counsel on October 26, 2004.

unable to provide counsel with a statutorily required litigation report in enough time for counsel to prepare a response to the complaint. This enlargement is necessary to ensure adequate time The additional

for the agency to prepare a litigation report.

time requested is also necessary for undersigned counsel to confer with the agency, to prepare a thorough response, and to

Case 1:04-cv-01470-LJB

Document 6

Filed 11/04/2004

Page 2 of 3

obtain the necessary supervisory review of the Government's response. For the foregoing reasons, defendant respectfully requests the Court to grant this motion for enlargement of time of thirty (30) days, to and including, December 15, 2004, within which to file a response to the plaintiff's complaint.

Respectfully submitted, PETER KEISLER Assistant Attorney General DAVID M. COHEN Director

S/ DONALD E. KINNER DONALD E. KINNER Assistant Director

November 4, 2004

S/ CRISTINA C. ASHWORTH CRISTINA C. ASHWORTH Trial Attorney Commercial Litigation Branch Department of Justice Attn: Classification Unit 8th Floor 1100 L Street Washington, D.C. 20530 Tele: (202)307-0314 Attorneys for Defendant

2

Case 1:04-cv-01470-LJB

Document 6

Filed 11/04/2004

Page 3 of 3

CERTIFICATE OF SERVICE I, the undersigned, hereby certify under penalty of perjury that on this 4TH day of November, 2004, I caused to be served by United States mail (first class mail, postage prepaid) copies of "DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME" addressed as follows:

Michael Moran The Law Office of Curtis C. Coon, LLC 305 W. Chesapeake Avenue Suite 105 Towson, MD 21204

S/ CRISTINA C. ASHWORTH