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

Case 1:07-cv-00322-JPW

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Filed 06/04/2007

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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 Defendant, the United States, respectfully requests the Court to grant an enlargement of time of two days, to and including June 7, 2007, within which to file declarations, pursuant to the Court's order, dated May 25, 2007. declarations are currently due on June 5, 2007. Our

This is our

first request for an enlargement of time for this purpose. Counsel for the plaintiff, Input/Output Technologies, Inc. ("Input"), has authorized us to say that Input does not oppose this motion for an enlargement of time. Substantial progress has been made collecting documents and drafting declarations in order to demonstrate the relevant regulatory schemes, and to demonstrate how the relevant requirements were met in this case. yet complete. However, this work is not

In part, our efforts were slowed by the Memorial

Day holiday and by the fact that some employees took additional leave near the holiday. However, the main reason that we need

extra time is because we are trying to be particularly thorough in our presentation.

Case 1:07-cv-00322-JPW

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Filed 06/04/2007

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The full enlargement of time is in the interests of justice and judicial economy. We believe that an additional two days These

will permit us time to prepare more thorough declarations.

additional efforts by the witnesses are likely to shorten the length of the proceedings overall by clarifying the relevant legal and factual issues, if any, remaining in this case. For the reasons stated above, we respectfully request that our unopposed motion be granted. Respectfully submitted, PETER D. KEISLER Assistant Attorney General JEANNE E. DAVIDSON Director S/ Steven J. Gillingham STEVEN J. GILLINGHAM Assistant Director 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 June 4, 2007 Attorneys for Defendant

Case 1:07-cv-00322-JPW

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Filed 06/04/2007

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CERTIFICATE OF FILING I hereby certify that on June 4, 2007, a copy of the foregoing "DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME" 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. the Court's system. S/ James W. Poirier Parties may access this filing through