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

Case 1:07-cv-00740-LMB

Document 44

Filed 01/14/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS BID PROTEST

CALIFORNIA INDUSTRIAL FACILITIES RESOURCES, INC. dba CAMSS SHELTERS Plaintiff, v. THE UNITED STATES OF AMERICA,

Defendant.

and ALASKA STRUCTURES, INC. Intervenor

) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

No. 07-740C (Judge Baskir)

PLAINTIFF'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Pursuant to Rule 6(b) and 6.1 of the Rules of the United States Court of Federal Claims, plaintiff, California Industrial Facilities Resources, Inc. dba CAMSS Shelters ("CAMSS Shelters"), respectfully requests a four day enlargement of time, through and including January 22, 2008, within which to file its Reply to

Case 1:07-cv-00740-LMB

Document 44

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defendant's cross motion. When defendant requested its four day enlargement of time by motion dated January 9, 2008, counsel for plaintiff and substitute counsel for defendant discussed that defendant's motion would include a similar request for enlargement of time for plaintiff's Reply. That did not occur. Currently, counsel for plaintiff is on travel on the west coast and will not return to his office until January 20, 2008. Plaintiff's request for enlargement only includes one working day and should not necessitate a delay in the Court's schedule for oral argument on February 5, 2008. As part of this enlargement of time, plaintiff also requests that the date for the Consolidated Statement of Uncontroverted Facts be enlarged to coincide with Plaintiff's filing of its Reply--January 22, 2008. Defendant does not oppose this motion. This enlargement of time is requested to provide plaintiff with sufficient time to respond to defendant's pleading in light of the extension granted to defendant. For these reasons, defendant respectfully request that the Court grant this unopposed motion for enlargement of time.

Case 1:07-cv-00740-LMB

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Respectfully submitted,

s/ William A. Shook William A. Shook Kirkpatrick & Lockhart Preston Gates Ellis LLP 1601 K Street NW Washington, DC 20006 Tel: (202) 661-6256 Fax: (202) 778-9100 Date: January 14, 2008