Free Motion for Leave to Exceed Page Limit - District Court of Federal Claims - federal

Case 1:08-cv-00094-JPW

Document 26

Filed 05/16/2008

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS BID PROTEST TYLER CONSTRUCTION GROUP, Plaintiff, v. THE UNITED STATES, Defendant. : : : : : : : : :

No. 08-94C (Judge Wiese)

PLAINTIFF'S UNOPPOSED MOTION TO EXCEED PAGE LIMITS FOR ITS MEMORANDUM OF LAW IN OPPOSITION TO DEFENDANT'S MOTION FOR JUDGMENT UPON THE ADMINISTRATIVE RECORD AND PLAINTIFF'S REPLY TO DEFENDANT'S RESPONSE TO PLAINTIFF'S MOTION FOR JUDGMENT UPON THE ADMINISTRATIVE RECORD The Plaintiff respectfully requests that this Honorable Court permit the Plaintiff to exceed the page limits set forth in Rule 5.3(b). The Plaintiff has consulted with Defendant's counsel and he does not oppose this motion. The Plaintiff asserts that the Plaintiff's protest addresses issues of national significance involving a new method of procurement being applied by the Corps of Engineers in the procurement of major construction projects on a regional and national basis. As such, the complexity of the legal issues presented, and the matters raised in Defendant's memorandum of law, requires an extension of the page limits set forth in Rule 5.3(b). The Plaintiff, therefore, respectfully requests this Honorable Court's permission to submit a memorandum of law not to exceed 35 pages. CONCLUSION For the reasons stated above, the Plaintiff respectfully requests that its motion to exceed the page limit be granted.

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Case 1:08-cv-00094-JPW

Document 26

Filed 05/16/2008

Page 2 of 2

Respectfully submitted,

Dated: May 16, 2008

/s/ Michael H. Payne_____ Michael H. Payne, Esquire Payne Hackenbracht & Sullivan 220 Commerce Dr., Suite 100 Ft. Washington, PA 19034 215-542-2777 215-542-2779(fax) [email protected] Attorney of Record for TYLER CONSTRUCTION GROUP

OF COUNSEL: Joseph A. Hackenbracht, Esquire Timothy A. Sullivan, Esquire Payne Hackenbracht & Sullivan