Case 1:07-cv-00150-GWM
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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
Document 28
Filed 03/30/2007
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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