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

Case 1:07-cv-00680-FMA

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Filed 11/14/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS 5860 Chicago Ridge LLC, Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) )

No. 07-680 (Judge Allegra)

DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Pursuant to Rule 6(b) of the Rules of the United States Court of Federal Claims ("RCFC"), defendant requests an enlargement of time of 30 days, to and including December 19, 2007, within which to respond to the complaint. presently due on November 19, 2006. Our response is

This is our first request Plaintiff's counsel

for an enlargement of time for this purpose.

has been contacted and does not oppose this request for an enlargement of time. Upon assignment of this matter, defendant's counsel promptly requested, pursuant to 28 U.S.C. § 520, that the appropriate agency provide him with a litigation report. Agency counsel

recently informed us, however, that additional time will be necessary for that agency to provide its litigation report. Agency counsel has assured defendant's counsel that the agency expects to deliver its litigation report on or before November 30, 2007. Upon receipt of the litigation report, defendant's

counsel will require time to study it and determine the most appropriate response to the complaint. Therefore, we anticipate

that an additional 30 days will be required to prepare our

Case 1:07-cv-00680-FMA

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response. For the foregoing reasons, defendant requests that the Court grant this motion for an enlargement of time.

Respectfully submitted, PETER D. KEISLER Assistant Attorney General JEANNE E. DAVIDSON Director s/ Kirk T. Manhardt KIRK T. MANHARDT Assistant Director s/ Robert E. Chandler ROBERT E. CHANDLER 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) 307-1011 Attorneys for Defendant November 14, 2007

Case 1:07-cv-00680-FMA

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CERTIFICATE OF FILING

I hereby certify that on this 14th day of November 2007, 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. filing through the Court's system. Parties may access this

s/ Robert E. Chandler