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

Case 1:07-cv-00898-LAS

Document 5

Filed 02/20/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS GULF GROUP, INC., Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 07-898C (Sr. Judge Smith)

DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME Pursuant to Rule 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 26, 2008, to respond to the complaint filed by plaintiff, Gulf Group, Inc. Our response to the complaint currently is due on February 25, 2008. This is the first request for an enlargement of time. Counsel for the parties have discussed this motion and its request for relief, and plaintiff's counsel has represented that plaintiff does not oppose this request. The requested enlargement is necessary because we did not receive the agency's litigation report until February 15, 2008, and we did not receive a copy of the voluminous contract documents until February 19, 2008. We require a 30-day enlargement of time to review the litigation report and contract documents, analyze the complaint, confer and coordinate with agency counsel, and respond appropriately by answer or motion.

Case 1:07-cv-00898-LAS

Document 5

Filed 02/20/2008

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For the foregoing reasons, we respectfully request that the Court grant this unopposed motion for a 30-day enlargement of time, to and including March 26, 2008, for the United States to respond to the complaint. Respectfully submitted,

JEFFREY S. BUCHOLTZ Acting Assistant Attorney General

JEANNE E. DAVIDSON Director

s/Steven J. Gillingham STEVEN J. GILLINGHAM Assistant Director

s/Douglas G. Edelschick DOUGLAS G. EDELSCHICK Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L. Street, N.W. Washington, DC 20530 Tel: (202) 353-9303 February 20, 2008 Attorneys for Defendant

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Case 1:07-cv-00898-LAS

Document 5

Filed 02/20/2008

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that on February 20, 2008, a copy of 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/Douglas G. Edelschick

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