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

Case 1:07-cv-00322-JPW

Document 29

Filed 07/27/2007

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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 UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME TO FILE THE ADMINISTRATIVE RECORD, AND DEFENDANT'S 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 3, 2007, within which to file the administrative record. This filing is due on or before July 27, 2007. This is

our first request for an enlargement of time for this purpose. 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 July 31, 2007 be rescheduled to a date and time convenient to the Court no earlier than August 7, 2007. Counsel for Input has authorized us to state that Input does not oppose this motion. make this motion. In fact, counsel for Input requested that we It is our understanding that counsel for Input

seeks to have an opportunity to review the administrative record, and to consult with his client about the administrative record, before discussing this case and any schedule with the Court.

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The full enlargement requested is needed.

A substantial

volume of documents have been gathered, and listed in a draft notice. However, certain questions have arisen concerning the

proper scope of the administrative record, and further consultations between counsel for the United States and the agency are necessary before the final administrative record may be designated. In addition, it may be necessary to ship

additional documents from Ohio to counsel's office in Washington, D.C. 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 July 31, 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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Case 1:07-cv-00322-JPW

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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 July 27, 2007 Attorneys for Defendant

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CERTIFICATE OF FILING I hereby certify that on July 27, 2007, a copy of the foregoing "DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME TO FILE THE ADMINISTRATIVE RECORD, AND DEFENDANT'S UNOPPOSED 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. system. S/ James W. Poirier Parties may access this filing through the Court's