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

Case 1:07-cv-00243-LMB

Document 39

Filed 06/18/2007

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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 May 31, 2007 scheduling order by enlarging the deadline for the parties' consolidated statement of facts ("CSF") by nine days, until June 27, 2007. The CSF is currently due today, June 18, 2007. This is our first request for an enlargement of time for this purpose. Counsel for plaintiff, The Ravens Group, Inc. ("Ravens"), and intervenor, Rowe Contracting Services, Inc. ("Rowe"), have authorized us to state that they support this motion.

Case 1:07-cv-00243-LMB

Document 39

Filed 06/18/2007

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This enlargement is requested because schedule conflicts have made it difficult for counsel to confer concerning the CSF. Counsel for the Government traveled to Jacksonville, Florida, on June 7, 2007, and to Huntsville, Alabama, on June 11-13, 2007 for depositions in Tetra Tech, EC, Inc., v. United States, Fed. Cl. No. 06-146. Counsel for Rowe will be traveling the week of June 18-22, 2007, for a family vacation. Counsel for Ravens will be out of the office on June 25-26, 2007, due to a prior travel commitment. Accordingly, the parties request an enlargement so that counsel may have additional time to confer and agree upon the CSF. For the foregoing reasons, we respectfully request that the Court grant our motion to enlarge the deadline for the CSF by nine days, until June 27, 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 18, 2007 Attorneys for Defendant

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Case 1:07-cv-00243-LMB

Document 39

Filed 06/18/2007

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CERTIFICATE OF SERVICE I hereby certify that on June 18, 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