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

Case 1:07-cv-00740-LMB

Document 20

Filed 10/30/2007

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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, Defendant, v. ALASKA STRUCTURES,INC., Intervenor. ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

No. 07-740 (Judge Lawrence M. Baskir)

DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME AND TO AMEND THE BRIEFING SCHEDULE Pursuant to Rule 6(b) and 6.1 of the Rules of the United States Court of Federal Claims, defendant, the United States, respectfully requests a one-day enlargement of time, through and including November 9, 2007, within which to file its Motion for Judgment Upon the Administrative Record and an amendment to the remaining deadlines to the briefing schedule as set forth in this motion. Our motion is currently due on November 8, 2007. This is defendant's first request for an enlargement of time for this purpose. The plaintiff and intervenor, through their respective counsel, have been contacted regarding this request and do not oppose this motion. This enlargement is requested because, at the time of the status conference setting the current briefing schedule, Government counsel was unaware that agency counsel would be out of the office and unreachable from November 7-8, 2007, and from November 26-30, 2007.

Case 1:07-cv-00740-LMB

Document 20

Filed 10/30/2007

Page 2 of 3

Moreover, Government counsel is scheduled to be a panelist at the National Asian Pacific American Bar Association convention in Nevada and will be on travel from November 14-19, 2007. As a result of these commitments, the Government respectfully requests that the briefing schedule in this matter be amended as follows: November 9, 2007 Defendant's/Intervenor's Motion for Judgment on the Administrative Record Filed Plaintiff's Response/Cross-Motion for Judgment on the Administrative Record Filed Defendant's/Intervenor's Response to Plaintiff's CrossMotion and Defendant's/Intervenor's Reply on its Motion Filed Plaintiff's Reply on its Cross-Motion and Parties' Consolidated Statement of Uncontroverted Facts Filed Tentative Date for Oral Argument

November 21, 2007

December 3, 2007

December 10, 2007

December 13, 2007

For these reasons, defendant respectfully requests that the Court grant this unopposed motion for enlargement of time. Respectfully submitted, PETER D. KEISLER Assistant Attorney General JEANNE E. DAVIDSON Director s/Harold D. Lester, Jr. HAROLD D. LESTER, JR. Assistant Director

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Case 1:07-cv-00740-LMB

Document 20

Filed 10/30/2007

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s/Marla T. Conneely MARLA T. CONNEELY Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit, 8th Floor 1100 L Street, N.W. Washington, D.C. 20530 Tel: (202) 305-3689 Fax: (202) 305-7643

October 30, 2007

Attorneys for Defendant

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