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

Case 1:08-cv-00005-MCW

Document 7

Filed 02/19/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS VITAL RECORDS CONTROL OF FLORIDA, LLC, Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) )

No. 08-05C (Judge Williams)

DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME Pursuant to Rules 6(b)(1) and 6.1 of the Rules of the United States Court of Federal Claims ("RCFC"), defendant, the United States, respectfully requests a 21-day enlargement of time, to and including March 24, 2008, within which to file a response to the complaint. The response to the complaint is currently due on March 3, 2008. This is our first request for an enlargement of time. Plaintiff's counsel has represented that plaintiff, Vital Records Control of Florida, LLC ("Vital Records"), has no objection to this motion. A litigation report has been provided by the agency pursuant to 28 U.S.C. § 520(b). Nevertheless, we require additional time to coordinate the contents of our response to plaintiff's complaint with the agency because agency counsel has been out of the office on work-related travel. Additionally, counsel of record was out of the office for trial advocacy training at the National Advocacy Center from January 28, 2008, through February 8, 2008, and was therefore unable to communicate with agency counsel about the specifics of this case until last week. For these reasons, defendant respectfully requests that the Court grant this motion for an enlargement of time by 21 days, to and including March 24, 2008, within which to file a response to the complaint.

Case 1:08-cv-00005-MCW

Document 7

Filed 02/19/2008

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Respectfully submitted, JEFFREY S. BUCHOLTZ Acting Assistant Attorney General JEANNE E. DAVIDSON Director s/Patricia M. McCarthy PATRICIA M. McCARTHY Assistant Director s/ Dawn E. Goodman DAWN E. GOODMAN Trial Attorney Commercial Litigation Branch Civil Division U.S. Department of Justice Attn: Classification Unit, 8th Floor 1100 L Street, N.W. Washington, DC 20530 Tel: (202) 616-1067 Fax: (202) 514-8624 February 19, 2008 Attorneys for Defendant

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Case 1:08-cv-00005-MCW

Document 7

Filed 02/19/2008

Page 3 of 3

CERTIFICATE OF FILING I hereby certify that on this 19th day of February, 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/ Dawn E. Goodman DAWN E. GOODMAN