Free Motion for Extension of Time to File Response/Reply - District Court of Federal Claims - federal

Case 1:07-cv-00150-GWM

Document 37

Filed 04/19/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS (Bid Protest) HERITAGE OF AMERICA, LLC, Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) )

No. 07-150 (Judge George W. Miller)

MOTION TO ENLARGE TIME TO FILE REPLY AND RESPONSE Pursuant to Rule 6(b) of the Rules of the United States Court of Federal Claims, Plaintiff Heritage of America, LLC (HOA) respectfully requests a two-day enlargement of time in which it may file its reply in support of its motion for judgment upon the administrative record and response to the cross motions for judgment upon the administrative record brought by Defendant United States and the Defendants-Intervenors. HOA's reply and response is presently due on April 24, 2007, and the enlargement will move the deadline to April 26, 2007. Defendants consent to this enlargement. HOA requests this enlargement because its counsel requires additional time to complete its reply and response. HOA previously consented to and the Court ordered a two-day

enlargement of time for the Defendants to file their responses and cross motions. This reduced by two days the amount of time HOA was granted under the original briefing schedule to file its reply and response. Due to the volume of Defendants' briefing, HOA has now determined that it needs these additional two days restored to the briefing schedule.

Case 1:07-cv-00150-GWM

Document 37

Filed 04/19/2007

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A two-day enlargement will not materially prejudice the Defendants, whose reply briefs in support of their cross motions are due on May 1, 2007. HOA therefore respectfully requests a two-day enlargement.

LEWIS AND ROCA JONTZ DAWE, LLP

By

/s/ Ross L. Crown Ross L. Crown Attorneys for Heritage of America, LLC P.O. Box 1027 Albuquerque, New Mexico 87103 (505) 764-5402 (505) 764-5463 19 April 2007

Dated:

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245715.1

Case 1:07-cv-00150-GWM

Document 37

Filed 04/19/2007

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CERTIFICATE OF SERVICE

I hereby certify that on April 19, 2007, a copy of the foregoing "Motion to Enlarge Time to File Reply and Response" 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/ Ross L. Crown Ross L. Crown

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