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

Case 1:08-cv-00191-FMA

Document 17

Filed 09/04/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS CHENEGA TECHNOLOGY SERVICES CORPORATION, Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 08-191C (Judge Allegra)

DEFENDANT'S MOTION FOR AN ENLARGEMENT OF TIME Defendant respectfully requests an enlargement of time of 14 days, to and including September 25, 2008, within which to file its reply to plaintiff's opposition to defendant's motion to dismiss and motion for summary judgment. Defendant's response is currently due on September 11, 2008. This is our first request for an enlargement of time for this purpose. Plaintiff's counsel does not oppose this extension. Counsel is currently working on several matters, which have required counsel's attention and make this request necessary. These matters include (1) City Line Joint Venture v. United States, No. 96-738 (Fed. Cl.), in which the parties participated in a status conference regarding damages on September 3, 2008, with another conference scheduled for September 11, 2008, and in which the parties are attempting to negotiate a potential settlement; and (2) Brickwood Contractors, Inc. v. United States, No. 06-695 (Fed. Cl.), in which the Government is in the process of responding to discovery requests which are due on September 10, 2008. For the foregoing reasons, we respectfully request the Court to grant our motion for an enlargement of time of 14 days.

Case 1:08-cv-00191-FMA

Document 17

Filed 09/04/2008

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Respectfully submitted,

GREGORY G. KATSAS Assistant Attorney General

JEANNE E. DAVIDSON Director

s/Reginald T. Blades, Jr. REGINALD T. BLADES, JR. Assistant Director

s/Sean M. Dunn SEAN DUNN Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 1100 L Street, N.W., 8th Floor Washington, D.C. 20530 Tele: (202) 616-0883 Fax: (202) 353-7988 September 4, 2008 Attorneys for Defendant

Case 1:08-cv-00191-FMA

Document 17

Filed 09/04/2008

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CERTIFICATE OF FILING I hereby certify that on this 4th day of September 2008, a copy of the foregoing "Defendant's Motion For An Enlargment 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/Sean M. Dunn

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