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

Case 1:08-cv-00501-LJB

Document 7

Filed 09/02/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS

PUBLIC SERVICE COMPANY OF OKLAHOMA,

Plaintiff, v. THE UNITED STATES, Defendant.

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No. 08-501 (Judge Bush)

DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME Pursuant to Rule 6(b) of the Rules of the United States Court of Federal Claims, defendant, the United States, respectfully requests a 30-day enlargement of time, to and including October 8, 2008, within which to respond to plaintiff's complaint. Our response is currently due on September 8, 2008. We have not previously requested an enlargement of time for this purpose. Counsel for plaintiff indicated on September 2, 2008 that plaintiff is not opposed to this motion. We received the agency's litigation report, required by 28 U.S.C. § 520(b), on August 27, 2008. This 30-day request is necessary to provide the Government with an opportunity to review the litigation report and analyze the factual and legal issues related to the complaint. We anticipate that the 30-day enlargement will provide sufficient time for defendant's counsel to gather necessary information, to review the litigation report, and to respond to the complaint. For these reasons, we respectfully request that the Court grant our unopposed motion for an enlargement of time of 30 days, to and including October 8, 2008, within which to respond to plaintiff's complaint.

Case 1:08-cv-00501-LJB

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Filed 09/02/2008

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Respectfully submitted,

GREGORY G. KATSAS Assistant Attorney General

JEANNE E. DAVIDSON Director

/s/Martin F. Hockey, Jr. MARTIN F. HOCKEY, JR. Assistant Director

/s/ Kent C. Kiffner KENT C. KIFFNER Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit, 8th Fl. 1100 L. St. NW Washington, DC 20530 Telephone: (202) 353-0536 Facsimile: (202) 307-0972 Attorneys for Defendant

September 2, 2008

Case 1:08-cv-00501-LJB

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Filed 09/02/2008

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CERTIFICATE OF ELECTRONIC FILING I hereby certify that on September 2, 2008, 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/ Kent C. Kiffner