In response to the Plaintiff, the United States Coast Guard has all intentions to defend within this case however the delays that you mention of have been uncontrollable. Unfortunately, we can not prevent our defense counselor from being deported from the island. Under the reasons of your motion, they were out of our control and therefore we shouldn't be penalized for island matters. At no point has the Coast Guard intentionally caused delays or showed no intentions to not represent. The plaintiff also mentions that the defendant has never requested an extension however it is to be known that on this thread it can be seen multiple times requesting and even being granted an extension, this is plainly a false and untrue statement. In addition to this, Attorney Goldstein, the motion that you request for has a basis of findings from the court of indisputable fact however this case is surrounded by uncertainty and disputed facts and information. For the aforementioned reasoning, your honor, the defense counsel requests that the motion for summary judgment be quashed.