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

Case 1:08-cv-00358-EJD

Document 10

Filed 08/13/2008

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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 14 days, to and including August 28, 2008, within which to file our response to the complaint. Our response is currently due by August 14, 2008.

This is our second request for an enlargement of time for this purpose, the Court having granted us an enlargement of 30 days. Counsel for plaintiff, TKC Communications, LLC ("TKC"), has authorized us to state that TKC does not oppose this motion. Counsel for the United States has been in communication with counsel for the agency regarding this matter for several weeks. In particular, efforts have been underway to gather relevant documents. Some documents were received last week. A draft

response to the complaint was anticipated daily, and for that reason no motion for an enlargement of time was filed last week. However, counsel did not receive a draft response to the complaint from the agency until August 13, 2008.

Case 1:08-cv-00358-EJD

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Filed 08/13/2008

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The full enlargement of time requested is needed.

Time is

needed to complete necessary research, and to make any necessary corrections to the draft response. In addition, time is needed

for review of the final draft answer 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 August 13, 2008 Attorneys for Defendant

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Case 1:08-cv-00358-EJD

Document 10

Filed 08/13/2008

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CERTIFICATE OF FILING I hereby certify that on August 13, 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