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

Case 1:05-cv-00586-MCW

Document 9

Filed 10/03/2005

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS DANKA DE PUERTO RICO, INC., Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) No. 05-586C ) (Judge Williams) ) ) )

DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Defendant respectfully requests an enlargement of time of 30 days, to and including November 2, 2005, within which to respond to plaintiff's complaint. Defendant's response to plaintiff's This is our

complaint is currently due on October 3, 2005.

second request for an enlargement of time for this purpose. Plaintiff's counsel has indicated that plaintiff does not oppose this motion. In addition, upon receipt of the complaint, defendant's counsel promptly forwarded it to the United States Property and Fiscal Officer for review and assistance. This case involves a

Puerto Rican contractor performing a contract in Puerto Rico. The unusual location of this case has contributed to the further extension of time that is required for defendant's counsel to gather information and points of contact for the case. The

further enlargement is necessary to permit defendant's counsel to continue to gather the necessary information to respond to plaintiff's complaint, prepare the appropriate response, obtain supervisory review, and file it.

Case 1:05-cv-00586-MCW

Document 9

Filed 10/03/2005

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For the foregoing reasons, we respectfully request the Court to grant our unopposed out of time motion for an enlargement of time of 30 days. Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director s/Harold D. Lester, Jr. HAROLD D. LESTER, JR. Assistant Director s/Brian S. Smith BRIAN S. SMITH Attorney Commercial Litigation Branch Civil Division Department of Justice Washington, D. C. 20530 Tele: (202) 616-0391 Fax: (202) 353-7988 Attorneys for Defendant October 3, 2005

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Case 1:05-cv-00586-MCW

Document 9

Filed 10/03/2005

Page 3 of 3

CERTIFICATE OF FILING I hereby certify that on October 3, 2005, a copy of 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/Brian S. Smith

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