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

Case 1:07-cv-00055-TCW

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS BID PROTEST CHE CONSULTING, INC., ) ) ) ) ) ) ) ) ) ) )

Plaintiff, v. THE UNITED STATES, Defendant.

No. 07-55C (Judge Wheeler )

DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT Pursuant to Rule 6.1 of the Rules of this Court ("RCFC"), defendant respectfully requests the Court to enlarge by seven days, to and including August 20, 2007, the time within which it must furnish any response to plaintiff's second motion for judgment upon the administrative record and file our own renewed motion for judgment upon the administrative record. Defendant's response and cross-motion is currently due on August 13, 2007, by order of this Court dated July 13, 2007. This is defendant's first request for an enlargement of time for this purpose. Plaintiff's and intervenor's counsel do not oppose this motion, nor an extension of all remaining deadlines by one week. Counsel for the Government has recently been involved in the drafting and filing of our initial appellate brief in Slattery v. United States, Fed. Cir. No. 2007-5063; the filing of our opposition to a motion for preliminary injunction, the filing of the administrative record, and presenting our arguments in another bid protest, Meeks Disposal, Inc. v. United States, Court of Federal Claims No. 07-544C; and post-decision processing in Bank of America v. United States, Fed. Cir. No. 2006-5088. Finally, intervenor's counsel, whose brief is due at the same time as

Case 1:07-cv-00055-TCW

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ours, informed us today that he broke his shoulder yesterday, so would appreciate having an additional week as well. The additional days are needed for finalization of our brief and to allow sufficient time for review. For the foregoing reasons, defendant respectfully requests that the Court grant this unopposed motion. Respectfully submitted, PETER D. KEISLER Assistant Attorney General JEANNE E. DAVIDSON Director

s/Brian M. Simkin by s/Kathryn A. Bleecker BRIAN M. SIMKIN Assistant Director

OF COUNSEL: ANDREW SINN, ESQ. Assistant Regional Counsel U.S. GSA Office of Regional Counsel (4L) 77 Forsyth St., Suite 600 Atlanta, GA 30303 Tel: (404) 331-1535 Fax: (404) 331-1231

s/F. Jefferson Hughes F. JEFFERSON HUGHES Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L Street, N.W. Washington, D.C. 20530 Tel: (202) 305-3067 Fax: (202) 514-8640 Attorneys for Defendant

Dated: August 9, 2007

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Case 1:07-cv-00055-TCW

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CERTIFICATE OF FILING I hereby certify that on this 9th day of August, 2007, a copy of the foregoing "DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT" 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/ F. Jefferson Hughes