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


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Date: June 19, 2008
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Case 1:07-cv-00707-CFL

Document 19

Filed 06/19/2008

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS DAVID WHALEN, et. al., Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 07-707 (Judge Lettow)

JOINT MOTION FOR ENLAGEMENT OF TIME Pursuant to Rule 6.1 of the Rules of this Court ("RCFC"), the parties respectfully request a 14-day enlargement of time within which to file the joint proposed status report. Currently, the joint proposed status report is due on June 23, 2008. The extension would bring the due date to July 7, 2008. This is the parties' first request for an enlargement of time for this purpose. This 14-day enlargement of time is necessitated by the fact that plaintiffs' counsel substituted into the case on May 30, 2008, and needs additional time to gather information necessary to identify the relevant factual and legal issues of the case and set forth a discovery plan. See RCFC App. A ΒΆ 4. Additionally, defendant's counsel was assigned a new bid protest on June 16, 2008, Weston Solutions, Inc. v. United States, Fed. Cl. No. 08-444C, and will likely have objections to supplementation of the administrative record due on June 24, 2008 in another bid protest, RKR Joint Venture, LLC v. United States, Fed. Cl. No. 08-62C.

Case 1:07-cv-00707-CFL

Document 19

Filed 06/19/2008

Page 2 of 2

For these reasons, the parties respectfully request that the Court grant the parties' joint motion for a 14-day enlargement of time within which to file the joint proposed status report. Respectfully submitted, By: s/ Alexander R. Wheeler ALEXANDER R. WHEELER R. Rex Parris Law Firm 42220 10th St. West, Suite 109 Lancaster, CA 93534 Tele: (661) 949-2595 Fax: (661) 949-7524 Attorneys for Plaintiffs GREGORY G. KATSAS Acting Assistant Attorney General JEANNE E. DAVIDSON Director s/ Todd M. Hughes TODD M. HUGHES Deputy Director s/ William P. Rayel WILLIAM P. RAYEL Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit, 8th Floor 1100 L St., NW Washington, DC 20005 Tele: (202) 616-0302 Fax: (202) 307-0972 Attorneys for Defendant Dated: June 19, 2008

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