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

Case 1:03-cv-00623-LSM

Document 10

Filed 08/25/2003

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS U.S. Financial Corp. Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 03-623C (Senior Judge Margolis)

DEFENDANT'S MOTION FOR AN ENLARGEMENT OF TIME Pursuant to Rule 6.1 of the Rules of the United States Court of Federal Claims ("RCFC"), defendant respectfully requests an eight-day enlargement of time, to and including September 2, 2003, to file a response to the complaint filed by plaintiff, U.S. Financial Corp. due on August 25, 2003. enlargement of time. Our response is currently

This is our fourth request for an

We were unable to contact plaintiff's

counsel to ascertain his position on this request. The requested enlargement of time is necessary to obtain the necessary approval from an authorized representative of the Attorney General to file a third-party complaint against The W.I.N.N. Group ("WINN"). The undersigned counsel has

completed an initial draft of our answer to the complaint, of a motion to summon a third party, of a third party complaint, and of a memorandum requesting the necessary approval. However, we are still evaluating our strategy in this case and require additional time to finalize our response.

Case 1:03-cv-00623-LSM

Document 10

Filed 08/25/2003

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For the foregoing reasons, we respectfully request that the Court grant our motion to enlarge the time within which we may respond to the plaintiff's complaint by eight days, to and including September 2, 2003. Respectfully submitted,

ROBERT D. McCALLUM, JR. Assistant Attorney General

DAVID M. COHEN Director /s Mark A. Melnick MARK A. MELNICK Assistant Director /s Margaret E. McGhee MARGARET E. McGHEE Attorney Commercial Litigation Branch Civil Division Department of Justice 1100 L Street, N.W. Attn: Classification Unit 8th Floor Washington, DC 20530 Tel. (202) 305-3634 Fax. (202) 514-8624 August 25, 2003 Attorneys for Defendant

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Case 1:03-cv-00623-LSM

Document 10

Filed 08/25/2003

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CERTIFICATE OF FILING I hereby certify that on August 25, 2003, a copy of the foregoing "DEFENDANT'S UNOPPOSED 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/ Margaret E. McGhee