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

Case 1:07-cv-00899-NBF

Document 10

Filed 02/25/2008

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

No. 07-899C (Judge Firestone)

DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Pursuant to Rules 6(b) and 6.1 of the Rules of the United States Court of Federal Claims ("RCFC"), defendant, the United States, respectfully requests a 30-day enlargement of time, to and including March 29, 2008, within which to file a response to the complaint filed by plaintiff, Paradigm Learning, Inc. Our response is currently due on February 28, 2008. Plaintiff's counsel does not oppose our request. This is our first request for an enlargement of time for this purpose. Agency counsel needs additional time in which to collect documents. Due to the complexity of the issues involved in the case and the volume of material, the additional time requested is necessary for agency counsel to collect documents and for defendant's counsel to review the case file, coordinate with the agency, and to prepare an appropriate response to the complaint. For the these reasons, we respectfully request that the Court grant our unopposed motion to enlarge the time within which to respond to the complaint, by 30 days, to and including March 29, 2008.

Case 1:07-cv-00899-NBF

Document 10

Filed 02/25/2008

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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 February 25, 2008 Attorneys for Defendant

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Case 1:07-cv-00899-NBF

Document 10

Filed 02/25/2008

Page 3 of 3

CERTIFICATE OF FILING

I hereby certify that on the 25th day of February, 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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