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

Case 1:06-cv-00425-NBF

Document 23

Filed 06/20/2006

Page 1 of 3

IN THE UNITED STATES COURT OF FEDERAL CLAIMS (BID PROTEST) __________________________________________ ) INTERSPIRO, INC., ) ) and ) ) SCOTT TECHNOLOGIES, INC., d/b/a ) SCOTT HEALTH & SAFETY ) ) Plaintiffs, ) ) v. ) ) UNITED STATES, ) No. 06-425 ) (Consolidated with No. 06-443) Defendant, ) Judge N. Firestone ) and ) ) MINE SAFETY APPLIANCES CO. ) ) Intervenor. ) __________________________________________) UNOPPOSED MOTION FOR ENLARGEMENT OF TIME TO FILE AMENDED COMPLAINTS Pursuant to Rules 6 and 6.1 of the Rules of the United States Court of Federal Claims, Scott Technologies, Inc., doing business as Scott Health & Safety ("Scott"), respectfully requests that this Court enlarge the time within which Plaintiffs must file Amended Complaints. Presently, the deadline for filing Amended Complaints is Wednesday, June 21, 2006. Scott requests that this date be extended three (3) business days to Monday, June 26, 2006. The time for filing Amended Complaints has not previously been enlarged, and this is Scott's first request for an enlargement of time. This Unopposed Motion for Enlargement of Time is based upon the fact that Plaintiffs recently received sections of the Administrative Record ("AR") on Monday, June 19, 2006. 1

Case 1:06-cv-00425-NBF

Document 23

Filed 06/20/2006

Page 2 of 3

Scott requests that Plaintiffs be given the additional three business days to consider this new AR material in determining whether to file Amended Complaints. Scott has discussed this motion with counsel for Interspiro, Inc., Defendant, and Intervenor, and has been informed that all parties consent to this motion. A proposed Order is attached. Respectfully submitted,

s/ Daniel P. Graham__________ Rand L. Allen WILEY REIN & FIELDING LLP 1776 K Street, N.W. Washington, DC 20006 (202) 719-3193 (O) (202) 719-7049 (F) [email protected] June 20, 2006 Of counsel: John A. McCullough Daniel P. Graham William J. Grimaldi WILEY REIN & FIELDING LLP Bruce S. Ramo TYCO INTERNATIONAL, LTD. 9 Roszel Road Princeton NJ 08540 (609) 720-4306 (O) (609) 720-4335 (F) Counsel for Plaintiff

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Case 1:06-cv-00425-NBF

Document 23

Filed 06/20/2006

Page 3 of 3

IN THE UNITED STATES COURT OF FEDERAL CLAIMS (BID PROTEST) __________________________________________ ) INTERSPIRO, INC., ) ) and ) ) SCOTT TECHNOLOGIES, INC., d/b/a ) SCOTT HEALTH & SAFETY ) ) Plaintiffs, ) ) v. ) ) UNITED STATES, ) No. 06-425 ) (Consolidated with No. 06-443) Defendant, ) Judge N. Firestone ) and ) ) MINE SAFETY APPLIANCES CO. ) ) Intervenor. ) __________________________________________) ORDER Plaintiff Scott Technologies, Inc., doing business as Scott Health & Safety, has moved for an enlargement of the time within which Plaintiffs must file Amended Complaints. Having considered this Motion, as well as all other relevant materials and arguments, it is hereby ORDERED that the Motion be and hereby is GRANTED, and that the filing date for Plaintiffs' Amended Complaints is extended to June 26, 2006.

__________________________________ NANCY B. FIRESTONE Judge Dated: June __, 2006

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