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

Case 1:07-cv-00280-LJB

Document 26

Filed 06/11/2007

Page 1 of 2

UNITED STATES COURT OF FEDERAL CLAIMS _____________________________________ IRONCLAD-EEI, A Joint Venture, Plaintiff, v. UNITED STATES, Defendant, and CAMPBELL ROOFING & CONSTRUCTION, INC., MGC/CAMPBELL ROOFING & CONSTRUCTION, INC., Intervenor-defendants. ______________________________________ PLAINTIFF'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME Plaintiff, Ironclad-EEI ("plaintiff"), respectfully moves the Court for an enlargement of time to file its brief on the administrative record and states as follows: On or about June 5, 2007, counsel for plaintiff reviewed the administrative record for the first time. Counsel for plaintiff recently completed its review of the record, but found it to be deficient in some respects. As such, undersigned counsel contacted counsel for defendant and advised that plaintiff would need to conduct some additional document discovery. To this end, plaintiff's counsel is in the process of putting together a list of additional documents which it would like defendant to produce and add to the administrative record. Counsel for defendant advised she will review the discovery requests and attempt to resolve the matter directly with undersigned counsel. In light of the foregoing, plaintiff respectfully requests that the Court grant an enlargement of 1 Case No. 07-280C (Judge Bush)

Case 1:07-cv-00280-LJB

Document 26

Filed 06/11/2007

Page 2 of 2

thirty (30) days for plaintiff to file its brief on the record, and a corresponding enlargement to the deadlines that follow (defendant's brief on the record, oral argument). Plaintiff has discussed the relief herein with counsel for defendant who advised that she will not oppose the motion. WHEREFORE, based on the foregoing, plaintiff respectfully request an enlargement of thirty (30) days from June 21, 2007 to July 23, 2007 within which to file its brief on the administrative record, and a corresponding enlargement to all dates that follow on the Court's scheduling order. Dated: June 11, 2007 Respectfully submitted,

/s/ Kevin M. Cox Kevin M. Cox Camardo Law Firm, P.C. 127 Genesee Street Auburn, New York 13021 Tel: (315) 252-3846 Fax: (315) 252-3508 Attorneys for Plaintiff

CERTIFICATE OF SERVICE I hereby certify that on this 11th day of June, 2007, a copy of Plaintiff's Unopposed Motion for 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. Parties may access this filing through the Court's system. /s/ Kevin M. Cox Kevin M. Cox

2