Free Motion for Extension of Time to File Response/Reply - District Court of Federal Claims - federal

Case 1:03-cv-02033-NBF

Document 52

Filed 07/14/2006

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS COMMERCIAL CASUALTY INSURANCE COMPANY OF GEORGIA, Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) )

No. 03-2033C (Judge Firestone)

DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME Defendant, the United States, respectfully requests the Court to grant an enlargement of time of 21 days, to and including August 18, 2006, to file defendant's response to plaintiff's motion for reconsideration and motion for summary judgment. By order dated June 20, 2006, our response is currently due on July 28, 2006. The Court previously granted our request for an enlargement of 32 days. Counsel for plaintiff advised that he does not oppose this motion. The Government requests the enlargement because counsel for the Government has other commitments that require a substantial amount of her time. In particular, counsel is required to be in Albuquerque, New Mexico, from July 17 through July 19, 2006, for ADR proceedings in Silver State Construction Co. v. United States, Fed. Cl. No. 05-978. Counsel for the Government is also required to a cross-motion for summary judgment in a bid protest proceeding, Interspiro, Inc. v. United States, Fed. Cl. No. 06-425, and Scott Technologies, Inc. v. United States, Fed. Cl. No. 06-443, on August 7, 2006.

Case 1:03-cv-02033-NBF

Document 52

Filed 07/14/2006

Page 2 of 2

For the foregoing reasons, we respectfully request the Court to grant defendant's motion for an enlargement of time. Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director s/ Donald E. Kinner DONALD E. KINNER Assistant Director s/ Doris S. Finnerman DORIS S. FINNERMAN Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L Street, N.W. Washington, D.C. 20530 Department of Justice Tel: (202) 307-0300 Fax: (202) 305-7643 Attorneys for Defendant July 14, 2006