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

Case 1:07-cv-00150-GWM

Document 15

Filed 03/20/2007

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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 nine-day enlargement of time to file the administrative record. The administrative record is currently due on March 21, 2007, and the enlargement will move the deadline to March 30, 2007. The

United States previously sought a six-day enlargement, which the Court granted. All parties consent.

The United States requests this additional time after conferring with the parties about the administrative record that will be needed in this case. The parties believe that a jointly-

stipulated, "abbreviated administrative record" can be filed in this case and will significantly conserve both the parties' and the Court's resources. The Government sent a preliminary

proposal for the contents of the record to all counsel on Monday, March 20, 2007, but all parties agree that they need further time to review all materials to ensure that the necessary documents

Case 1:07-cv-00150-GWM

Document 15

Filed 03/20/2007

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are provided to the Court. this nine-day enlargement.

We therefore respectfully request

Respectfully submitted, PETER D. KEISLER Assistant Attorney General JEANNE E. DAVIDSON Director s/ Mark A. Melnick for 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 20, 2007 Attorneys for Defendant

Case 1:07-cv-00150-GWM

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Filed 03/20/2007

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CERTIFICATE OF FILING I hereby certify that on March 20, 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