Free Motion to Expedite - District Court of Federal Claims - federal

Case 1:08-cv-00021-BAF

Document 19

Filed 01/31/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS Bid Protest

Savantage Financial Services, Inc.,

Plaintiff,
v.
)

No. 1:08-cv-21 (Judge Futey)

THE UNITED STATES,

Defendant.

MOTION FOR EXPEDITED CONSIDERATION AND FOR AN ENLARGEMENT OF TIME
On January 31, 2008, Plaintiff filed a Motion to Compel Removal of Documents from the Protective Order ("Motion to Compel"). According to the Court's Notice of Electronic

Filing with respect to the Motion to Compel, Defendant has until February 19, 2008 to respond to that Motion. As the Court is aware, however, Plaintiff's Motion for Summary Judgment is due on Tuesday, February 5, 2008. Unless expedited action is taken with respect
to the Motion to Compel, Plaintiff will not have all of the information it believes is necessary

to fully address all of the issues before the Court. Plaintiff recommends that the Motion to
Compel be resolved via pleadings and a telephonic conference.

4667673.1

Case 1:08-cv-00021-BAF

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Accordingly, Plaintiff respectfully requests that the Court consider Plaintiff's Motion to

Compel on an expedited basis. If the Court should grant Plaintiff's Motion to Compel,
Plaintiff also requests that it be provided an additional five working days to file its initial brief.
Respectfully submitted,

s/ Timothy Sullivan Timothy Suffivan 1909 K Street, N.W., 6th Floor

Washington, D.C. 20006
(202) 585-6930 (tel.) (202) 508-1028 (fax)

Attorney of Record for Plaintiff Savantage Financial Services, Inc. Of Counsel:

Katherine S. Nucci Thompson Cobum LLP 1909 K Street, N.W., 6th Floor

Washington, D.C. 20006
(202) 585-6900 (tel.) (202) 585-6969 (fax)

Dated: January 31, 2008

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Filed 01/31/2008

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CERTIFICATE OF FILING
I hereby certify that on the 31st day of January 2008, a copy of Plaintiff's Motion For

Expedited Consideration And For An Enlargement of Time was filed electronically. I

understand that notice of this filing will be sent to all parties by operation of the Court's electronic filing system. Parties may access this filing through the Court's system.

/s Timothy Sullivan

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