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

Case 1:07-cv-00243-LMB

Document 44

Filed 06/27/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS BID PROTEST THE RAVENS GROUP, INC., Plaintiff, v. THE UNITED STATES, Defendant, and ROWE CONTRACTING SERVICES, INC., Intervenor. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

No. 07-243C (Judge Baskir)

DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Defendant, the United States, respectfully requests that the Court modify the June 19, 2007 scheduling order by enlarging the deadline for the parties' consolidated statement of facts ("CSF") by two days, until June 29, 2007. The CSF is currently due today, June 27, 2007. This is our second request for an enlargement of time for this purpose. We previously obtained one enlargement of nine days. Counsel for plaintiff, The Ravens Group, Inc. ("Ravens"), and intervenor, Rowe Contracting Services, Inc. ("Rowe"), have authorized us to state that they support this

Case 1:07-cv-00243-LMB

Document 44

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motion. This enlargement is requested because counsel require additional time to prepare and execute a final draft of the CSF. Counsel for all three parties have worked diligently toward completing the CSF, and participated in a teleconference earlier today to discuss the final version. We request this short enlargement to give counsel for Rowe additional time in which to prepare and circulate a final draft, and to give counsel for the Government additional time to submit the final draft for supervisory review. For the foregoing reasons, we respectfully request that the Court grant our motion to enlarge the deadline for the CSF by two days, until June 29, 2007.

Respectfully submitted, PETER D. KEISLER Assistant Attorney General JEANNE E. DAVIDSON Director s/ Franklin E. White, Jr. FRANKLIN E. WHITE, JR. Assistant Director

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Case 1:07-cv-00243-LMB

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s/ Roger A. Hipp ROGER A. HIPP Trial Attorney U.S. Department of Justice Civil Division Commercial Litigation Branch 1100 L St., N.W. Attn: Class. Unit - 8th Fl. Washington, D.C. 20530 Tel.: (202) 305-3091 June 27, 2007 Attorneys for Defendant

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Case 1:07-cv-00243-LMB

Document 44

Filed 06/27/2007

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CERTIFICATE OF SERVICE I hereby certify that on June 27, 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. Parties may access this filing through the Court's system.

s/ Roger A. Hipp