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

Case 1:07-cv-00150-GWM

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Filed 04/09/2007

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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 CROSS-MOTIONS Pursuant to Rule 6(b) of the Rules of the United States Court of Federal Claims, the United States respectfully requests a two-day enlargement of time in which it and defendantsintervenors may file their responses and cross-motions for judgment upon the administrative record ("cross-motions"). The

cross-motions are due on April 10, 2007, and the enlargement will move the deadline to April 12, 2007.1 Plaintiff and defendant-

intervenor Evolver consent. We have not been able to contact counsel for defendant-intervenor Dynamic Systems. We request this enlargement because we need a small amount of additional time to coordinate with the agency and intervenors and complete our submission to the Court. Trial counsel for the

United States was out of the country last week on a working vacation and became ill, and this slowed the anticipated process

We do not anticipate that this enlargement will affect the other scheduled dates in this matter.

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Case 1:07-cv-00150-GWM

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of communication with the agency and defendants-intervenors and completion of the cross-motion. A two-day enlargement will not materially prejudice the plaintiff, whose reply and response are due on April 24, 2007. We therefore respectfully request a two-day enlargement. Respectfully submitted, PETER D. KEISLER Assistant Attorney General JEANNE E. DAVIDSON Director s/ Kathryn A. Bleecker KATHRYN A. BLEECKER Assistant Director s/ Brian T. Edmunds BRIAN T. EDMUNDS Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 1100 L Street, NW, 8th Floor Telephone: (202)616-8253 Telecopier:(202)307-0972 April 9, 2007 Attorneys for Defendant

Case 1:07-cv-00150-GWM

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CERTIFICATE OF FILING I hereby certify that on April 9, 2007, a copy of the foregoing "MOTION TO ENLARGE TIME TO FILE CROSS-MOTION" 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. system. Parties may access this filing through the Court's

s/Brian T. Edmunds