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

Case 1:08-cv-00094-JPW

Document 15

Filed 03/24/2008

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 SUPPORT OF ITS 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 an extension of the page limit is proper in this case because the Administrative Record encompasses 204 separately tabbed sections, some of which contain multiple documents amounting to over 5200 pages. This lengthy Administrative Record presents complex factual issues that the Plaintiff must address. In addition, 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 also 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 65 pages.

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Case 1:08-cv-00094-JPW

Document 15

Filed 03/24/2008

Page 2 of 2

CONCLUSION For the reasons stated above, the Plaintiff respectfully requests that its motion to exceed the page limit be granted. Respectfully submitted, Dated: March 24, 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