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

Case 1:07-cv-00899-NBF

Document 15

Filed 04/01/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS JAY JACKSON & ASSOCIATES, Plaintiff, v. UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 07-899C (Judge Firestone)

DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Pursuant to Rules 6(b)(2) and 6.1 of the Rules of the United States Court of Federal Claims ("RCFC"), defendant, the United States, respectfully requests a one-day enlargement of time, to and including April 1, 2008, within which to file, out of time, an answer to the complaint filed by plaintiff, Jay Jackson & Associates. Plaintiff's counsel does not oppose our request. Our answer was due on Monday, March 31, 2008. On Monday, undersigned defendant's counsel coordinated some last minute changes to our answer with agency counsel, with the mistaken belief that the answer was due on April 1. Through inadvertent oversight and excusable neglect, undersigned counsel missed the due date for filing our answer, for which counsel apologizes. For the these reasons, we respectfully request that the Court grant our unopposed motion to enlarge the time within which to answer the complaint, by one day, to and including April 1, 2008.

Case 1:07-cv-00899-NBF

Document 15

Filed 04/01/2008

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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/ Joseph A. Pixley JOSEPH A. PIXLEY Attorney Commercial Litigation Branch Civil Division Department of Justice 1100 L Street, N.W. Attn: Classification Unit 8th Floor Washington, DC 20530 Tel. (202) 307-0843 Fax. (202) 307-0972 April 1, 2008 Attorneys for Defendant

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Case 1:07-cv-00899-NBF

Document 15

Filed 04/01/2008

Page 3 of 3

CERTIFICATE OF FILING

I hereby certify that on the 1st day of April, 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. Parties may access this filing through the Court's system.

s/Joseph A. Pixley

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