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

Case 1:08-cv-00358-EJD

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS TKC COMMUNICATIONS, LLC, Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 08-358C (Chief Judge Damich)

DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Defendant, the United States, respectfully requests the Court to grant an enlargement of time of seven days, to and including September 18, 2008, within which to file our response to the complaint. 2008. Our response is currently due by September 11,

This is our fourth request for an enlargement of time for

this purpose, the Court having granted us enlargements of 30 days, 14 days and 14 days, respectively. Counsel for

plaintiff, TKC Communications, LLC ("TKC"), has authorized us to state that TKC does not oppose this motion. Counsel for the United States sent a number of detailed questions to agency counsel on or about September 4, 2008. Agency counsel organized a large meeting, and conducted numerous follow-up inquiries in order to prepare a response to our questions. Counsel for the United States received the agency

response on September 10, 2008, and has begun to incorporate the information into the draft response to the complaint. The full enlargement of time requested is needed. Time is

needed to complete any further necessary research, and to make

Case 1:08-cv-00358-EJD

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any further necessary corrections to the draft response.

In

addition, time is needed for review of the final draft response by counsel for the agency and supervisors at the Department of Justice. For the reasons set forth above, we respectfully request that the Court grant our unopposed motion for an enlargement of time. Respectfully submitted, GREGORY G. KATSAS Assistant Attorney General JEANNE E. DAVIDSON Director S/ Kirk T. Manhardt KIRK T. MANHARDT Assistant Director S/ James W. Poirier JAMES W. POIRIER Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor, 1100 L St, N.W. Washington, D.C. 20530 Tele: 202-616-0856 Fax: 202-514-7969 September 11, 2008 Attorneys for Defendant

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CERTIFICATE OF FILING I hereby certify that on September 11, 2008, 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. the Court's system. S/ James W. Poirier Parties may access this filing through