Free Motion to Amend Schedule - District Court of Federal Claims - federal

Case 1:08-cv-00101-LJB

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Filed 06/16/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS L-3 GLOBAL COMMUNICATIONS SOLUTIONS, INC., Plaintiff, v. ) ) ) ) ) ) ) ) ) ) )

No. 08-101C (bid protest) (Judge Bush)

THE UNITED STATES, Defendant.

DEFENDANT'S UNOPPOSED MOTION TO MODIFY THE BRIEFING SCHEDULE Pursuant to Rules 6(b) and 6.1 of the Rules of the United States Court of Federal Claims ("RCFC"), defendant, the United States, respectfully requests that the Court modify the remaining briefing schedule in this bid protest. Because of a power outage in downtown Washington, D.C., on June 13, 2008, counsel for defendant's office building and this Court were closed for the day. Therefore, defendant was unable to file its motion for judgment upon the administrative record, due on June 13, 2008, until June 16, 2008, the next business day. Accordingly, counsel for the parties have discussed modifying the current briefing schedule so that both parties have the same time allotted in the current briefing schedule to file their remaining briefs in this matter. Defendant's counsel has proposed the following modified briefing schedule, to which plaintiff's counsel has agreed: plaintiff's response to defendant's cross-motion for judgment upon the administrative record and reply in support of plaintiff's motion for judgment upon the administrative record, shall be due on or before July 7, 2008; defendant's reply in support of its motion for judgment upon the administrative record, shall be due on or before July 17, 2008. Oral argument would remain as scheduled for July 30, 2008, unless the Court should wish to

Case 1:08-cv-00101-LJB

Document 33

Filed 06/16/2008

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modify that date as well. Accordingly, we respectfully request that the Court grant our unopposed motion to modify the remaining briefing schedule in this matter to permit both parties sufficient time to file their final briefs in this matter. Respectfully submitted, GREGORY G. KATSAS Acting Assistant Attorney General JEANNE E. DAVIDSON Director

s/Deborah A. Bynum DEBORAH A. BYNUM Assistant Director OF COUNSEL: TALBOT J. NICHOLAS II Attorney Office of Procurement Law United States Coast Guard 2100 2nd Street, S.W. Washington, D.C. 20593-0001 s/Dawn S. Conrad DAWN S. CONRAD Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit, 8th Floor 1100 L Street, N.W. Washington, D.C. 20530 Tel: (202) 616-2279 Fax: (202) 305-7643 Attorneys for Defendant

June 16, 2008

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Case 1:08-cv-00101-LJB

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Filed 06/16/2008

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CERTIFICATE OF SERVICE I hereby certify that on this 16th day of June, 2008, a copy of the foregoing "DEFENDANT'S UNOPPOSED MOTION TO MODIFY THE BRIEFING SCHEDULE" 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/Dawn S. Conrad