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

Case 1:06-cv-00396-MCW

Document 33

Filed 12/22/2006

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In The United States Court of Federal Claims
BID PROTEST No. 06-396C (Judge Williams) L-3 COMMUNICATIONS INTEGRATED SYSTEMS L.P., Plaintiff, v. THE UNITED STATES, Defendant, and LOCKHEED MARTIN AERONAUTICS COMPANY, Intervenor.

MOTION FOR ENLARGEMENT OF TIME

Pursuant to Rule 6.1 of the Rules of the U.S. Court of Federal Claims, L-3 Communications Integrated Systems L.P. ("L-3") submits this Motion for Enlargement of Time and would show the Court as follows: 1. On December 21, 2006, this Court ordered L-3 to file an Amended Complaint by

January 19, 2007. 2. The Court also ordered Defendant to produce the Druyun Study or documents

memorializing the study by that date. 3. Lead counsel for L-3 is scheduled to be in Mexico City for an arbitration from

January 3 through January 21, 2007.

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Case 1:06-cv-00396-MCW

Document 33

Filed 12/22/2006

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4.

Because of this extensive time commitment immediately following the holidays,

L-3 asks for an enlargement of time of 21 days to February 9, 2007 for filing an Amended Complaint. 5. The United States does not oppose this request for relief and has asked that its

filing likewise be due on February 9, 2007. 6. 7. 8. Intervenor Lockheed Martin Aeronautics Company opposes the relief requested. L-3 has not made any previous request for enlargement of time. This request is not made for purposes of delay but that justice may be done.

WHEREFORE, L-3 respectfully requests the Court to issue an order enlarging the time until February 9, 2007 to file the materials that are the subject of its December 21, 2006 order. Respectfully submitted,

Dated: December 22, 2006

s/ Paul W. Searles Paul W. Searles HAYNES AND BOONE, LLP 901 Main Street 3100 Bank of America Plaza Dallas, Texas 75202 Telephone: (214) 651-5197 Telecopier: (214) 200-0705 ATTORNEYS FOR L-3 COMMUNICATIONS INTEGRATED SYSTEMS L.P.

Of Counsel: Sharon N. Freytag HAYNES AND BOONE, LLP 901 Main Street 3100 Bank of America Plaza Dallas, Texas 75202 Telephone: (214) 651-5586 Telecopier: (214) 200-0450
D-1493465_1.DOC

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