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

Case 1:05-cv-01245-EJD

Document 6

Filed 01/23/2006

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS ____________________________________ ) ZOYA ATAMIRZAYEVA, ) ) Plaintiff, ) ) No. 05-1245L v. ) ) Honorable Edward J. Damich UNITED STATES OF AMERICA, ) ) Defendant. ) ____________________________________) _______________________________________________________ UNOPPOSED MOTION FOR ENLARGEMENT OF TIME _______________________________________________________ The United States, pursuant to RCFC 6(b), requests an enlargement of time of eighteen (18) days, to and including February 17, 2006, in which to respond to Plaintiffs' Complaint. The United States' Answer is currently due January 30, 2006. The United States requests this short enlargement of time to provide counsel an opportunity to coordinate with representatives from the Department of State, including agency personal currently stationed at the United States embassy in Tashkent, Uzbekistan, whose participation is required in this case. The complexity and sensitivity of the issues raised in this case require counsel and the Department of State to conduct a thorough preliminary analysis of the case prior to filing a response to the complaint. The United States has not previously sought an extension of time to respond to Plaintiff's Complaint. This extension will not impact the parties' abilities to meet future deadlines in this case. Counsel for the United States contacted Plaintiff's counsel regarding this request. Plaintiff's counsel consents to the request and does not oppose the granting of this motion.

Case 1:05-cv-01245-EJD

Document 6

Filed 01/23/2006

Page 2 of 2

Accordingly, the United States respectfully requests that the Court grant it an eighteen (18) day extension, to and including February 17, 2006, in which to respond to Plaintiffs' Complaint.

January 23, 2006

Respectfully Submitted,

SUE ELLEN WOOLDRIDGE Assistant Attorney General Environment and Natural Resources Division /s/ James D. Gette ________________________________ JAMES D. GETTE Trial Attorney Natural Resources Section Environment and Natural Resources Division United States Department of Justice P.O. Box 663 Washington, DC 20044-0663 (202) 305-1461 (202) 305-0506 (Fax)

2