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

Case 1:08-cv-00261-LAS

Document 38

Filed 05/21/2008

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS BID PROTEST

WATTS-HEALY TIBBITTS A JV

Plaintiff, v. THE UNITED STATES, Defendant, And IBC/TOA Corporation, Defendant-Intervenor.

: : : : : : : : : : : : : : : :

No. 08-261C (Senior Judge Smith)

PLAINTIFF'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME Pursuant to RCFC 6(b)(1) and 6.1, Plaintiff, Watts-Healy Tibbitts A JV, by its counsel respectfully requests a 6-day enlargement of time, to and including June 2, 2008, to file Plaintiff's replies to Defendant's Opposition To Plaintiff's Second Motion For A Temporary Restraining Order And Preliminary Injunction and Defendant-Intervenor's Response To Plaintiff's Second Motion For Preliminary Injunctive Relief. This is Plaintiff's first request for an enlargement of time for this purpose. Plaintiff's counsel has consulted with counsel for the Defendant and Defendant-Intervenor, and Defendant and Defendant-Intervenor have no objection to this request. In accordance with the Court's directions during the conference on May 19, 2008, the Administrative Record in this matter will not be filed until Friday, May 23, 2008, while under

Case 1:08-cv-00261-LAS

Document 38

Filed 05/21/2008

Page 2 of 2

the current scheduling order, Plaintiff's reply is due on Tuesday, May 27, 2008. An enlargement of time will enable Plaintiff's counsel to devote the time necessary to review the Administrative Record and prepare a full reply to Defendant's and Defendant-Intervenor's responses. An enlargement of time until June 2, 2008 will still afford the Court, Defendant, and DefendantIntervenor with a full week before the Oral Argument scheduled for June 9, 2008. For the foregoing reasons, Plaintiff respectfully requests that the Court grant the unopposed motion for enlargement of time of six days, to and including June 2, 2008 for Plaintiff's replies to Defendant's Opposition To Plaintiff's Second Motion For A Temporary Restraining Order And Preliminary Injunction and Defendant-Intervenor's Response To Plaintiff's Second Motion For Preliminary Injunctive Relief. Respectfully submitted,

Dated: May 21, 2008

/s/ Michael H. Payne Michael H. Payne, Esquire Payne Hackenbracht & Sullivan 220 Commerce Drive, Suite 100 Fort Washington, PA 19034 Tel: (215) 542-2777 Fax: (215) 542-2779 [email protected] Attorney of Record for Watts-Healy Tibbitts A JV

Of Counsel: Joseph A. Hackenbracht, Esquire Payne Hackenbracht & Sullivan

2