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

Case 1:07-cv-00897-ECH

Document 27

Filed 01/08/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS BID PROTEST

) LOGISTICS SUPPORT SERVICES JV, ) ) Plaintiff, ) ) v. ) ) THE UNITED STATES ) OF AMERICA, ) ) Defendant. ) ) and ) ) SANTA BARBARA ) APPLIED RESEARCH, INC., ) ) Intervenor )

Civil Action No. 07-897 (Judge Emily C. Hewitt)

PLAINTIFF'S MOTION FOR AN EXTENSION OF TIME IN WHICH TO FILE ITS MOTION TO SUPPLEMENT THE ADMINISTRATIVE RECORD COMES NOW Plaintiff Logistics Support Services JV ("LSSJV"), by and through the undersigned counsel, and hereby moves this Court to grant a one day extension of the current, January 8, 2008 deadline for plaintiff to file its motion to supplement the administrative record. The grounds of this motion were discussed in a conference call with chambers and the parties this morning. They are based on plaintiff's receipt this morning of numerous supplemental emails that the Department of Justice plans to add to the administrative record.

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Case 1:07-cv-00897-ECH

Document 27

Filed 01/08/2008

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WHEREFORE plaintiff requests the Court to grant this motion and permit plaintiff to file its motion to supplement on or before 5 pm on Wednesday, January 9, 2008.

Respectfully submitted,

By: s/ David S. Cohen Cohen Mohr, LLP 1055 Thomas Jefferson St., NW Suite 504 Washington, DC 20007 (202) 342-2550 (telephone) (202) 342-6147 (facsimile) Attorney of Record for Plaintiff Logistics Support Services JV Of Counsel: John J. O'Brien Cohen Mohr, LLP 1055 Thomas Jefferson St., NW Suite 504 Washington, DC 20007 (202) 342-2550 (telephone) (202) 342-6147 (facsimile) Dated: January 8, 2008

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Case 1:07-cv-00897-ECH

Document 27

Filed 01/08/2008

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Certificate of Filing I hereby certify that on this 8th day of January 2008, a copy of the foregoing "Plaintiff's Motion For An Extension Of Time In Which To File Its Motion To Supplement The Administrative Record," 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/ David S. Cohen

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