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

Case 1:01-cv-00351-JFM

Document 57

Filed 11/14/2005

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS CLEARWATER CONSTRUCTORS, INC., ) ) Plaintiff, ) ) v. ) ) THE UNITED STATES, ) ) Defendant. )

No. 01-351C (Judge Merow)

DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME Defendant respectfully requests an enlargement of time of 14 calendar days, to and including December 5, 2005, for the Government to file its opposition to plaintiff's cross-motion for summary judgment and reply in support of our own motion for summary judgment ("the Government response"). The Government response is presently due November 21, 2005. This is defendant's first request for an enlargement of time for this matter. Government counsel has discussed this motion with plaintiff's counsel and represents that plaintiff does not oppose it. The reason for this request is that the agency's primary technical consultant in this case has been away from the office for the last week and we believe that his technical input will be helpful in formulating the Government response. In light of the upcoming Thanksgiving holiday, we expect that the two weeks requested will be sufficient to secure the agency's technical input and file our response. For the foregoing reasons, defendant respectfully requests that the Court grant this unopposed motion for an enlargement of time.

Case 1:01-cv-00351-JFM

Document 57

Filed 11/14/2005

Page 2 of 2

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

s/ James M. Kinsella JAMES M. KINSELLA Deputy Director

s/ J. Reid Prouty J. REID PROUTY Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor, 1100 L Street, NW Washington, D.C. 20530 Tel: (202) 305-7586 Fax: (202) 514-7969 November 14, 2005 Attorneys for Defendant

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