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

Case 1:06-cv-00506-SGB

Document 7

Filed 08/30/2006

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS SARANG CORPORATION, Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) )

No. 06-506 (Judge Braden)

DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Pursuant to Rule 6.1 of the Rules of the United States Court of Federal Claims ("RCFC"), defendant requests an enlargement of time of 60 days, to and including November 6, 2006, within which to respond to the complaint. September 5, 2006. Our response is presently due on

This is our first request for an enlargement Plaintiff's counsel has been contacted

of time for this purpose.

and does not oppose this request for an enlargement of time. As a result of discussions with both plaintiff's counsel and agency counsel, the undersigned counsel believes that this case may be resolved through an agreement of the parties. We

anticipate that an additional 60 days will be required to collect and review the documents relevant to the issues, conduct discussions between the parties and obtain approval should an agreement be reached. For the foregoing reasons, defendant requests that the Court grant this unopposed motion for an enlargement of time.

Case 1:06-cv-00506-SGB

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Filed 08/30/2006

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Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director s/ Mark A. Melnick MARK A. MELNICK 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 August 30, 2006

Case 1:06-cv-00506-SGB

Document 7

Filed 08/30/2006

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CERTIFICATE OF FILING

I hereby certify that on this 30th day of August, 2006, 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