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

Case 1:08-cv-00256-TCW

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Filed 06/02/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS J.E. MCAMIS, INC. Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) )

No. 08-256 (Judge Wheeler)

DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Pursuant to Rules 6.1 and 6(b) of the Rules of the United States Court of Federal Claims ("RCFC"), defendant requests an enlargement of time of 60 days, to and including August 8, 2008, within which to respond to the complaint. is due on June 9, 2008. Our response presently

This is our first request for an Plaintiff's counsel has

enlargement of time for this purpose.

been contacted and does not oppose this request for an enlargement of time. Upon being assigned this matter, defendant's counsel promptly requested, pursuant to 28 U.S.C. § 520, that the appropriate agency provide him with a litigation report. agency has informed defendant's counsel that it requires additional time to prepare and provide its litigation report. anticipate that an additional 60 days will be required for the agency to prepare the report and for defendant's counsel to review the report, determine the most appropriate course of action and obtain the necessary internal review and approval of defendant's response to the complaint. For the foregoing reasons, defendant respectfully requests We The

Case 1:08-cv-00256-TCW

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that the Court grant this unopposed motion for an enlargement of time.

Respectfully submitted, GREGORY G. KATSAS Acting Assistant Attorney General JEANNE E. DAVIDSON Director s/ Patricia M. McCarthy PATRICIA M. MCCARTHY Assistant Director s/ Robert E. Chandler Robert E. Chandler Trial Attorney Commercial Litigation Branch Civil Division Department of Justice 1100 L St., N.W. Attn: Classification Unit 8th Floor Washington, D.C. 20530 Tel: (202) 307-1011 Attorneys for Defendant June 2, 2008

Case 1:08-cv-00256-TCW

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CERTIFICATE OF FILING

I hereby certify that on this 2nd day of June 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. through the Court's system. Parties may access this filing

s/ Robert E. Chandler