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

Case 1:08-cv-00191-FMA

Document 11

Filed 08/18/2008

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS

) ) ) ) ) ) Defendant. ) ____________________________________)

CHENEGA TECHNOLOGY SERVICES CORPORATION, Plaintiff, v. THE UNITED STATES,

No. 08-191C Judge Allegra

PLAINTIFF'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Plaintiff respectfully requests an enlargement of time of seven (7) days, to and including August 25, 2008 within which to respond to defendant's Motion to Dismiss or for Summary Judgment. Plaintiff's response is currently due on August 18, 2008. This is the first request for an enlargement of time for this purpose. It will also be the only request for an enlargement of time. Defendant's counsel, Sean M. Dunn, Esq. has been contacted and stated that defendant does not oppose this motion and that Plaintiff may so state in this motion. Plaintiff represents a number of Alaska Native Corporations in connection with government contracts issues and SBA programs for small business. On August 11, 2008, the SBA Office of Inspector General released its Report Number 8-14: "Non-Native Managers Secured Millions Of Dollars From 8(A) Firms Owned By Alaska Native Corporations Through Unapproved Agreements That Jeopardized The Firms' Program Eligibility." The report is focused of two companies, one of which is my client ­ Cape Fox Corporation. The publication of the report was accompanied by a blizzard of activity, including the delivery of a notice of

Case 1:08-cv-00191-FMA

Document 11

Filed 08/18/2008

Page 2 of 2

suspension, notice of proposed termination and a requests for size determination. For my client and myself, this has been a exercise in continuous and time-consuming crisis management for the last week. I need and respectfully request another seven days in order to complete my response to the pending dispositive motions.

Respectfully submitted,

William K. Walker Walker Reausaw 888 17th Street, NS, Suite 1100 Washington, DC 20006 Tele: 202-857-7910 Fax 202-857-7912 Attorney for Plaintiff

August 18, 2008.