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

Case 1:07-cv-00881-JPW

Document 32

Filed 01/25/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS SDS INTERNATIONAL, INC., Plaintiff, v. THE UNITED STATES Defendant, and HiPk, INC., Defendant-Intervenor. ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

No. 07-881 (Judge Weise) Bid Protest

DEFENDANT-INTERVENOR'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Pursuant to Rule 6(b) of the Rules of the United States Court of Federal Claims ("RCFC"), intervenor requests an enlargement of time of 7 days, to and including February 1, 2008, within which to respond to plaintiff's motion for preliminary injunction. Our response presently is due on January 25, 2008. This is our second request for an enlargement of time for this purpose. Plaintiff and defendant have been contacted and neither plaintiff nor defendant will oppose this request for an enlargement of time. In addition, defendant has also sought, and has been granted, an identical enlargement of time. On January 16, 2008, intervenor requested an enlargement of time within which to respond to plaintiff's motion for preliminary injunction.1 After intervenor submitted its motion, on January 18, 2008, plaintiff amended its complaint.

1

The Court granted intervenor's motion on January 23, 2008.

Case 1:07-cv-00881-JPW

Document 32

Filed 01/25/2008

Page 2 of 3

Plaintiff's amended complaint contains several new allegations that intervenor intends to address in its briefing of the merits of in its response. Intervenor requires additional time to formulate an appropriate response to these new allegations. We therefore respectfully request that the Court grant intervenor's motion for an enlargement of time of seven days within which to file its response. Dated: January 25, 2008 Respectfully submitted, __/s/ J. Bradley Reaves_____________ J. Bradley Reaves, Esq. KAUFMAN & CANOLES, P.C. P.O. Box 3037 Norfolk, VA 23514-3037 (757) 624-3305 (757) 624-3169 - Fax [email protected] Counsel for Intervenor HiPk, LLC Of Counsel: Terence Murphy, Esq. P.O. Box 3037 Norfolk, VA 23514-3037 (757) 624-3139 (757) 624-3169 - Fax [email protected] Patrick H. O'Donnell, Esq. P.O. Box 3037 Norfolk, VA 23514-3037 (757) 624-3305 (757) 624-3169 - Fax [email protected]

Case 1:07-cv-00881-JPW

Document 32

Filed 01/25/2008

Page 3 of 3

CERTIFICATION OF FILING I hereby certify that on this 25th day of January 2008, a copy of the foregoing "INTERVENOR-DEFENDANT'S UNOPPOSED MOTION FOR 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/ J. Bradley Reaves_____________

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