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

Case 1:01-cv-00495-EGB

Document 289

Filed 08/17/2007

Page 1 of 3

IN THE UNITED STATES COURT OF FEDERAL CLAIMS KENT CHRISTOFFERSON et al., Plaintiffs, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 01-495C (Judge Bruggink)

DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Pursuant to Rule 6(b) of the Rules of the Court of Federal Claims, defendant respectfully requests an enlargement of time of 23 days, from August 20, 2007, to and including September 12, 2007, within which to respond to "Plaintiffs' Motion for a Protective Order." This is our first request for an enlargement of this period. Plaintiffs' counsel has informed us that plaintiffs do not oppose this motion. Since receiving plaintiffs' motion, the Bureau of Census ("Bureau") has begun to draft a response and collect relevant evidence. The Bureau has informed us that, due to vacations and the requirement for supervisory review, it will be unable to furnish us a draft response before next week. At that point, however, defendant's counsel expects to be on vacation and will be required to devote his time to other matters currently scheduled. Plaintiffs have suggested they may require an enlargement of time as well. As a result of these anticipated durations, the Court already has scheduled oral argument for the third week in October. For these reasons, defendant respectfully requests that the Court grant an enlargement of time of time of 23 days, from August 20, 2007, to and including September 12, 2007, within which to respond to "Plaintiffs' Motion for a Protective Order."

Case 1:01-cv-00495-EGB

Document 289

Filed 08/17/2007

Page 2 of 3

Respectfully submitted, PETER D. KEISLER Assistant Attorney General

JEANNE E. DAVIDSON Director

STEVEN J. GILLINGHAM Assistant Director Commercial Litigation Branch Civil Division Department of Justice 1100 L St. NW Attn: Classification Unit 8th Floor Washington, D.C. 20530 Tele: (202) 616-2311 Attorneys for Respondent August 17, 2007

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Case 1:01-cv-00495-EGB

Document 289

Filed 08/17/2007

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that, on August 17, 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/ Steven J. Gillingham