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

Case 1:08-cv-00186-NBF

Document 12

Filed 07/24/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS YVONNE BROWN, Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) )

No. 08-186C (Judge Firestone)

DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Pursuant to Rule 6(b)(1) of the Rules of the United States Court of Federal Claims, defendant, the United States, respectfully requests a seven-day enlargement of time, to and including July 31, 2008, within which to file a reply in support of our motion to dismiss the complaint. Our reply is currently due on July 24, 2008. This is defendant's first request for an enlargement of time. Plaintiff's counsel has authorized us to state that plaintiff does not oppose this motion. This enlargement is requested because the Government's trial attorney also represents the Government in a recently filed bid protest case, L-3 Communications Eotech, Inc. v. United States, No. 08-515C (Fed. Cl.). The complaint and motion for a temporary restraining order and other injunctive relief in that case was filed on July 15, 2008, one day after plaintiff Yvonne Brown filed her opposition to our motion to dismiss the complaint in this case. Pursuant to an expedited schedule, the Government's motion for judgment upon the administrative record in L-3 Communications is due on July 25, 2008. We request a short enlargement so that counsel may have adequate time to prepare both the Government's dispositive motion in L-3

Case 1:08-cv-00186-NBF

Document 12

Filed 07/24/2008

Page 2 of 3

Communications and the Government's reply brief in this case. We regret not filing this motion sooner. For the foregoing reasons, we respectfully request that the Court enlarge by seven days, from July 24, 2008, to July 31, 2008, the deadline for defendant's reply in support of its motion to dismiss the complaint. Respectfully submitted, GREGORY G. KATSAS Assistant Attorney General JEANNE E. DAVIDSON Director s/ Patricia M. McCarthy PATRICIA M. McCARTHY Assistant Director s/ Roger A. Hipp ROGER A. HIPP Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit, 8th Floor 1100 L Street, N.W. Washington, D.C. 20530 Tele: (202) 305-3091 Fax: (202) 514-8640 July 24, 2008 Attorneys for Defendant

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Case 1:08-cv-00186-NBF

Document 12

Filed 07/24/2008

Page 3 of 3

CERTIFICATE OF FILING I hereby certify that on July 24, 2008, a copy of the foregoing "DEFENDANT'S UNOPPOSED MOTION 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/ Roger A. Hipp

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