Free Motion to Amend Schedule - District Court of Federal Claims - federal

Case 1:07-cv-00740-LMB

Document 30

Filed 11/19/2007

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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. 07-740 (Judge Baskir)

PLAINTIFF'S MOTION FOR AN ENLARGEMENT OF TIME AND TO AMEND THE BRIEFING SCHEDULE Plaintiff, CALIFORNIA INDUSTRIAL FACILITIES RESOURCES, INC. dba CAMSS SHELTERS ("CAMSS Shelters" or "Plaintiff"), moves this Court pursuant to Rules 6(b) and 6.1 of the Rules of the Court of Federal Claims, to grant Plaintiff an enlargement of time in which to file its Response to Defendant's and Intervenor's Motions for Judgment on the Administrative Record and

Case 1:07-cv-00740-LMB

Document 30

Filed 11/19/2007

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Cross-Motion for Judgment on the Administrative Record. Plaintiff further respectfully requests that this Court amend the briefing schedule as detailed below. The tentative date for oral argument remains the same under Plaintiff's proposed schedule. Plaintiff's Response and Cross-Motion are currently due on November 21, 2007. This is Plaintiff's first request for an enlargement of time. We have contacted counsel for Defendant and Intervenor. Counsel for Defendant was unavailable and has not responded and counsel for Intervenor has stated that he will oppose the proposed briefing schedule. By order dated November 16, 2007, this Court required Defendant to produce additional documents relating to "the establishment of the salient physical, functional or performance specifications and independent testing requirements listed in Solicitation No. FA4452-07-Q-A055 that were created contemporaneously with the procurement." Defendant is required to provide these documents on or before November 30, 2007. In order to permit Plaintiff to review and respond to the documents required from the government in its Response and Cross-Motion, Plaintiff

Case 1:07-cv-00740-LMB

Document 30

Filed 11/19/2007

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respectfully requests that the Briefing Schedule be amended as follows: December 4, 2007: Plaintiff' Response/Cross-Motion for Judgment on the Administrative Record filed. Defendant's/Intervenor's Response to Plaintiff's Cross-Motion for Judgment on the Administrative Record and Defendant's/Intervenor's Reply on its Motion filed. Plaintiff's Reply on its Motion and Parties' Consolidated Statement of Uncontroverted Facts filed. Tentative Date for Oral Argument (at 10:00 a.m.).

December 11, 2007:

December 12, 2007:

December 13, 2007:

We therefore respectfully request that this court amend the briefing schedule as outlined above. 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: November 19, 2007