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

Case 1:06-cv-00396-MCW

Document 71

Filed 06/02/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS L-3 COMMUNICATIONS INTEGRATED ) SYSTEMS, L.P., ) ) Plaintiff, ) ) v. ) ) THE UNITED STATES, ) ) Defendant, ) ) and ) ) LOCKHEED MARTIN AERONAUTICS ) COMPANY, ) ) Intervenor. )

No. 06-396C (Judge Williams)

DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME Defendant respectfully requests, pursuant to Rule 6(a) of the Rules of the Court of Federal Claims ("RCFC"), that the Court grant an enlargement of time of six days from June 3, 2008 to June 9, 2007, for defendant to complete and file its reply brief to the plaintiff's opposition to defendant's motion to dismiss the amended complaint. Defendant's reply brief of defendant is due on June 3, 2008. This is the first request for an enlargement of time for this purpose. Defendant's counsel has discussed this motion with

counsel for plaintiff, and is authorized to state that plaintiff does not oppose this motion for enlargement of time. Defendant's

counsel also is authorized to state that counsel for the intervenor does not oppose the requested enlargement.

Case 1:06-cv-00396-MCW

Document 71

Filed 06/02/2008

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Defendant has begun preparation of its reply brief, but requires an additional six days to complete the preparation of the brief and its review by attorneys at both the agency and the Department of Justice. Further, since receipt of the plaintiff's

opposition to defendant's motion to dismiss, filed May 16, 2008, defendant's counsel was required among other things to be in Kansas City, MO, on May 19 and 20, 2008 to assist and advise the General Services Administration in their production of hundreds of boxes of documents for the plaintiff's counsel in AMEC Construction Management Inc. v. United States, Fed. Cl. No. 06867. Defendant's counsel also had to review numerous documents

and prepare responses to the plaintiff's requests for production of documents in that case that were directed to two witnesses, Martin A. Hom and Terry Page; those responses were served on the plaintiff on May 27, 2008. Defendant's counsel also had to

submit responses to the plaintiff's first set of interrogatories in that case; those responses were served on the plaintiff on May 30, 2008. Accordingly, defendant respectfully requests that the Court grant this unopposed motion for a six-day enlargement of time to June 9, 2008, for defendant to prepare and file its reply brief to plaintiff's opposition to defendant's motion to dismiss the amended complaint.

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Case 1:06-cv-00396-MCW

Document 71

Filed 06/02/2008

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Respectfully submitted, GREGORY G. KATSAS Acting Assistant Attorney General

s/Jeanne E. Davidson JEANNE E. DAVIDSON Director

s/Domenique Kirchner DOMENIQUE KIRCHNER Senior Trial Counsel Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L Street N.W. Washington, D.C. 20530 Tele: (202) 307-1111 Attorneys for Defendant Of Counsel: BRYAN R. O'BOYLE Senior Trial Attorney Department of Air Force Arlington, VA June 2, 2008

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