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

Case 1:08-cv-00101-LJB

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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 TO EXTEND DEFENDANT'S DEADLINE TO SUPPLEMENT THE ADMINISTRATIVE RECORD AND PLAINTIFF'S DEADLINE TO FILE A MOTION TO SUPPLEMENT THE ADMINISTRATIVE RECORD Plaintiff and Defendant mutually request that the Court grant a two-day extension for Defendant to supplement the administrative record and for Plaintiff, if necessary, to file a motion to supplement the administrative record and/or request further discovery. In support of this Motion, the parties state as follows: 1. On February 27, 2008, this Court's Order set forth the deadlines in

this case. Pursuant to this Order, Defendant was required to serve a CD-ROM of the Administrative Record by March 3, 2008, and Plaintiff was required to file a Motion to Supplement the Record by March 10, 2008 (Dkt. No. 8). 2. (Dkt. No. 11). 3. On March 7, 2008, this Court held a status conference in which On March 3, 2008, Defendant filed the Administrative Record

Defendant agreed to supplement the Administrative Record by March 10, 2008. At that

Case 1:08-cv-00101-LJB

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time, the Court extended the deadline for Plaintiff to file a motion to supplement the record or request further discovery to March 12, 2008. 4. It has come to the parties attention that the Agency requires

additional time in order to assemble documents that were missing from the Administrative Record. As a result, the parties have agreed that the Agency will provide a supplement to the Administrative Record by March 12, 2008. 5. Because Plaintiff will need some time in order to review the supplement to determine whether a motion to supplement the record or request further discovery is necessary, the parties have also agreed to extend that deadline by two days or until March 14, 2008. WHEREFORE, Plaintiff and Defendant request the Court to grant a twoday extension of the deadlines to Supplement the Administrative Record and file a Motion to Supplement the Administrative Record.

Dated: March 11, 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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CERTIFICATE OF SERVICE I hereby certify that the foregoing was electronically filed on March 11, 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.