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

Case 1:08-cv-00101-LJB

Document 29

Filed 05/30/2008

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

No. 08-101C

UNOPPOSED MOTION TO MODIFY SCHEDULING OF ORAL ARGUMENT Plaintiff L-3 Global Communications Solutions, Inc. respectfully submits this motion to modify the scheduling of oral argument that this Court has set for July 23, 2008. Counsel for the Defendant has represented that this motion is unopposed. Counsel of Record for Plaintiff, Ronald K. Henry, previously advised the Court that he expects to become a first-time grandfather in mid-July and will need to travel to Augusta, Georgia at that time. More recent sonogram testing has indicated that the pregnancy is not quite as far progressed as previously thought and that July 23 is now within the window of possible delivery dates. As a result, the parties have agreed to propose to the Court that oral argument be postponed by about a week to approximately July 30. Not necessary to this motion, but well within a Proud Poppa's bragging rights, counsel wishes to advise the Court and parties that his eldest daughter, Lori (aka "Poopsie") is near to completing the "Grand Slam" of four major transitions into the grown-up world. In May 2007, Poopsie graduated from college. In June 2007, she got her first big girl job. On Labor Day

Case 1:08-cv-00101-LJB

Document 29

Filed 05/30/2008

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weekend 2007, she married Elbert Nieves. Less than two months later, the pregnancy began. Daddy has always said that Lori is efficient and well-organized (end of Fatherly digression) Accordingly, Plaintiff respectfully requests the Court to set a new date for oral argument giving consideration to this recent change of events.

Dated: May 30, 2008

Respectfully submitted,

s/ Ronald K. Henry Ronald K. Henry KAYE SCHOLER, LLP 901 15th Street, NW Suite 1100 Washington, DC 20005 Phone: (202) 682-3500 Fax: (202) 682-3580 [email protected] Attorney for L-3 Global Communications Solutions, Inc.

Case 1:08-cv-00101-LJB

Document 29

Filed 05/30/2008

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CERTIFICATE OF SERVICE I hereby certify that the foregoing was electronically filed on May 30, 2008, with the Clerk of the Court for the United States Court of Federal Claims via the CM/ECF system. This system will send electronic notice of filing to the following individuals:

Dawn S. Conrad Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit, 8th Floor 1100 L Street, N.W. Washington, DC 20005 Tel: (202) 616-2279 Fax: (202) 305-7643 Attorney for Defendant

s/ Ronald K. Henry Ronald K. Henry KAYE SCHOLER, LLP 901 15th Street, NW Suite 1100 Washington, DC 20005 Phone: (202) 682-3500 Fax: (202) 682-3580 [email protected] Attorney for L-3 Global Communications Solutions, Inc.