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

Case 1:07-cv-00150-GWM

Document 28

Filed 03/30/2007

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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 ADMINISTRATIVE RECORD Pursuant to Rule 6(b) of the Rules of the United States Court of Federal Claims, the United States respectfully requests a four-day enlargement of time to file the administrative record. The administrative record is currently due on March 30, 2007, and the enlargement will move the deadline to April 3, 2007. The

United States previously sought six and nine-day enlargements, which the Court granted. All parties consent to this motion.

The United States requests this additional time to finish compiling the jointly-stipulated, "abbreviated administrative record" referred to in our previous filings. The Government sent

a preliminary proposal on March 20, 2007, to which plaintiff responded on March 28, 2007 and defendant-intervenors responded on March 29, 2007. Now that the United States has approval from

the parties, the record can be prepared, but we are informed that the task of compiling, paginating, and copying cannot be

Case 1:07-cv-00150-GWM

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completed before Tuesday, April 3, 2007. respectfully request this enlargement.

We therefore

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 March 30, 2007 Attorneys for Defendant

Case 1:07-cv-00150-GWM

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CERTIFICATE OF FILING I hereby certify that on March 30, 2007, a copy of foregoing "MOTION TO ENLARGE TIME TO FILE ADMINISTRATIVE RECORD" 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. the Court's system. Parties may access this filing through

s/Brian T. Edmunds