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

Case 1:07-cv-00863-RHH

Document 6

Filed 04/02/2008

Page 1 of 3

IN THE UNITED STATES COURT OF FEDERAL CLAIMS DONALD S. HUNTER, SR., Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 07-863C (Judge Hodges)

DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Pursuant to RCFC 6(b), defendant respectfully requests an enlargement of time of 31 days, to and including Monday, May 5, 2008, within which to respond to the complaint. Our response is now due on April 4, 2008. This is our first request for an enlargement of time for this purpose. Counsel for the plaintiff has indicated that he will not oppose this request for an enlargement of time. Counsel for the defendant timely requested, pursuant to 28 U.S.C. § 520, that the appropriate agency provide him with a litigation report. Agency counsel has been working to complete this report but has not yet been able to provide it to counsel for the defendant, principally because of the need to analyze several other cases the plaintiff has initiated, some or all of which may relate to his complaint in this case. Counsel for the defendant and agency counsel have discussed this issue, and we anticipate that the litigation report will be completed in the near future. After receiving the litigation report, counsel for the defendant will require time to study it and determine the most appropriate response to the complaint. Therefore, we anticipate that at least an additional 31 days will be required to prepare our response. For the foregoing reasons, defendant respectfully requests that the Court grant this unopposed motion for an enlargement of time.

Case 1:07-cv-00863-RHH

Document 6

Filed 04/02/2008

Page 2 of 3

Respectfully submitted, JEFFREY S. BUCHOLTZ Acting Assistant Attorney General JEANNE E. DAVIDSON Director s/ Reginald T. Blades, Jr. REGINALD T. BLADES, JR. Assistant Director s/ Devin A. Wolak DEVIN A. WOLAK 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) 616-0170 Fax. (202) 305-7644 April 2, 2008 Attorneys for Defendant

Case 1:07-cv-00863-RHH

Document 6

Filed 04/02/2008

Page 3 of 3

CERTIFICATE OF FILING

I hereby certify that on April 2, 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/ Devin A. Wolak