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

Case 1:07-cv-00322-JPW

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS INPUT/OUTPUT TECHNOLOGY, INC., Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 07-322C (Senior Judge Wiese)

DEFENDANT'S SECOND UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME TO FILE THE ADMINISTRATIVE RECORD, AND DEFENDANT'S SECOND UNOPPOSED MOTION TO RESCHEDULE THE STATUS CONFERENCE Defendant, the United States, respectfully requests the Court to grant an enlargement of time of seven days, to and including August 10, 2007, within which to file the administrative record. 2007. This filing is due on or before August 3,

This is our second request for an enlargement of time for

this purpose, the Court having granted an enlargement of seven days. Counsel for plaintiff, Input/Output Technologies, Inc.

("Input") has authorized us to state that Input does not oppose this motion. In addition, we respectfully request that the status conference scheduled for August 7, 2007 be rescheduled to a date and time convenient to the Court no earlier than August 14, 2007. Counsel for Input has authorized us to state that Input does not oppose this motion. The full enlargement requested is needed. A substantial

volume of documents has been gathered, but the documents need to

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be sorted and properly listed in order to make the administrative record easily comprehensible. Our motion is supported by the interests of justice and judicial economy. It would be possible for counsel for Input and

for the Court to cull through the documents and to determine where the most relevant documents are located. be burdensome and inefficient. However, it would

The United States seeks time to

organize the documents so that the review of those documents by Input and the Court will be easier. Once all the documents have been gathered, organized and described upon the draft notice, time will be needed for commercial copying. Time will also be needed for review of the

draft notice by counsel for the agency and by supervisors at the Department of Justice. For these reasons, we respectfully request that our unopposed motion for an enlargement of time be granted, and that the Court reschedule the status conference currently scheduled to be held on August 7, 2007. Respectfully submitted, PETER D. KEISLER Assistant Attorney General JEANNE E. DAVIDSON Director S/ Steven J. Gillingham STEVEN J. GILLINGHAM Assistant Director

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S/ James W. Poirier JAMES W. POIRIER Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor, 1100 L St, N.W Washington, D.C. 20530 Tele: 202-616-0856 Fax: 202-514-7969 August 1, 2007 Attorneys for Defendant

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CERTIFICATE OF FILING I hereby certify that on August 1, 2007, a copy of the foregoing "DEFENDANT'S SECOND MOTION FOR AN ENLARGEMENT OF TIME TO FILE THE ADMINISTRATIVE RECORD, AND DEFENDANT'S SECOND MOTION TO RESCHEDULE THE STATUS CONFERENCE" 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. may access this filing through the Court's system. S/ James W. Poirier Parties