Free Motion for Extension of Time to File Response/Reply - District Court of Federal Claims - federal

Case 1:08-cv-00094-JPW

Document 23

Filed 05/07/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS BID PROTEST

TYLER CONSTRUCTION GROUP, Plaintiff, v. THE UNITED STATES, Defendant.

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No. 08-94C (Judge Wiese)

PLAINTIFF'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME

Pursuant to RCFC 6(b)(1) and 6.1, Plaintiff, Tyler Construction Group, by its counsel respectfully requests a 10-day enlargement of time, to and including May 19, 2008, to file Plaintiff's response to Defendant's Motion for Judgment Upon the Administrative Record. This is Plaintiff's first request for an enlargement of time for this purpose. Plaintiff's counsel has consulted with counsel for the Defendant, and Defendant has no objection to this request. In addition to this action, attorney of record for the Plaintiff has been engaged in a number of other matters before this Court that have occupied his attention in recent weeks and will require his continued involvement in the coming week. An enlargement of time will enable Plaintiff's counsel to devote the time that this important case demands to complete a full reply to Defendant's response and to fully respond to Defendant's motion. For the foregoing reasons, Plaintiff respectfully requests that the Court grant the unopposed motion for enlargement of time of ten days, to and including May 19, 2008 for

Case 1:08-cv-00094-JPW

Document 23

Filed 05/07/2008

Page 2 of 2

Plaintiff's response to Defendant's Motion for Judgment Upon the Administrative Record. Respectfully submitted,

Dated: May 6, 2008

/s/ Michael H. Payne Michael H. Payne, Esquire Payne Hackenbracht & Sullivan 220 Commerce Drive, Suite 100 Fort Washington, PA 19034 Tel: (215) 542-2777 Fax: (213) 542-2779 [email protected] Attorney of Record for Tyler Construction Group

Of Counsel: Joseph A. Hackenbracht, Esquire Payne Hackenbracht & Sullivan

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