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

Case 1:06-cv-00706-CFL

Document 11

Filed 10/26/2006

Page 1 of 3

IN THE UNITED STATES COURT OF FEDERAL CLAIMS DIVERSIFIED MAINTENANCE, SYSTEMS, INC. Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) No. 06-706C ) (Judge Lettow) ) ) ) ) )

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, the United States, respectfully requests a 1-day enlargement of time, to and including October 30, 2006, within which to file the Government's motion for remand, and the administrative record. Our response is currently due on October 27, 2006. This is defendant's first request for an enlargement of time for this purpose. Defendant spoke with plaintiff's counsel, Mr. Timothy Willardson, to ascertain if he concurs with our request for an enlargement of time. He responded that he does not object to our request. Mr. Willardson response to the Government's motion is currently due November 3, 2006 and he indicated that based upon the Government's request for enlargement he may need until November 6, 2006 to file his response. The Government will not object to this extension. The enlargement is requested because the undersigned counsel of record for defendant requires further time to address, pursuant to the Court's request during the initial status conference, the procedures followed by the Small Business Administration in responding to a Hubzone certification protest, and compile the administrative record in a format suitable for electronic filing. For the foregoing reasons, defendant respectfully requests that the Court grant this motion

Case 1:06-cv-00706-CFL

Document 11

Filed 10/26/2006

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for an enlargement of time.

Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director

/s/ Bryant G. Snee BRYANT G. SNEE Assistant Director

/s/ Elizabeth Thomas ELIZABETH THOMAS Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L Street Washington, D.C. 20530 tel: (202) 353-4175 fax: (202) 307-0972 October 26, 2006 Attorneys for Defendant

Case 1:06-cv-00706-CFL

Document 11

Filed 10/26/2006

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that on October 26, 2006 a copy of the foregoing "DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME" was filed electronically. I understand that the notice of 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/ Elizabeth Thomas