Free Motion for Extension of Time - District Court of Federal Claims - federal

Case 1:08-cv-00101-LJB

Document 21

Filed 04/14/2008

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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

CONSENT MOTION FOR EXTENSION OF TIME TO FILE A REPLY MEMORANDUM IN SUPPORT OF PLAINTIFF'S MOTION FOR DISCOVERY AND SUPPLEMENTATION OF THE ADMINISTRATIVE RECORD Counsel for the parties have consulted and agreed to file this Motion for Extension of Time to File a Reply Memorandum in Support of Plaintiff's Motion for Discovery and Supplementation of the Administrative Record. Pursuant to the Court's briefing schedule, Plaintiff's reply memorandum is due today, April 14, 2008. Counsel, however, are continuing to work together to resolve the remaining issues regarding supplementation of the Administrative Record. The Department of Justice is presently working with the Coast Guard to identify additional documents for inclusion in the Administrative Record. As a result, the parties need additional time to reach a mutual resolution of the open issues surrounding the gaps in the Administrative Record. Accordingly, Plaintiff and Defendant jointly request that this Court extend the current schedule and that the parties will report to the Court on or before April 18, 2008, with respect to their success in resolving the remaining issues. At that time, Plaintiff will either withdraw its

Case 1:08-cv-00101-LJB

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Filed 04/14/2008

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Motion for Discovery and for Supplementation of the Administrative Record or the parties will jointly provide a proposed briefing schedule.

Dated: April 14, 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

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Filed 04/14/2008

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CERTIFICATE OF SERVICE I hereby certify that the foregoing was electronically filed on April 14, 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.