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

Case 1:06-cv-00312-TCW

Document 33

Filed 04/03/2008

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS MULTISERVICE JOINT VENTURE, LLC., Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) )

No. 06-312C (Judge Wheeler)

DEFENDANT'S CONSENT MOTION FOR AN ENLARGEMENT OF TIME Defendant respectfully requests that this Court grant an enlargement of time of 60 days with respect to each deadline specified in the Court's March 3, 2008 scheduling order. Currently, pursuant to that order, the parties' respective dispositive motions are due on or before April 18, 2008, responses on or before May 20, 2008, and replies on or before June 3, 2008. This is our first request for an enlargement of time for this purpose. Plaintiff consents to the instant motion. Undersigned counsel was only recently assigned this case on March 28, 2008. Additional time thus is required to enable newly assigned counsel to become familiar with the case, including to review the voluminous record, to meet with agency personnel, and to prepare our dispositive motion. For the foregoing reasons, defendant respectfully requests the Court to grant this motion for an enlargement of time of 60 days and, accordingly, to set the following briefing schedule: dispositive motions to be filed on or before June 17, 2008; responses to be filed on or before July 19, 2008; and replies to be filed on or before August 2, 2008.

Case 1:06-cv-00312-TCW

Document 33

Filed 04/03/2008

Page 2 of 2

Respectfully submitted, JEFFREY S. BUCHOLTZ Acting Assistant Attorney General JEANNE E. DAVIDSON Director s/ Martin F. Hockey, Jr. MARTIN F. HOCKEY, JR. Assistant Director s/ Matthew H. Solomson MATTHEW H. SOLOMSON Trial Attorney, Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit, 8th Floor 1100 L Street, N.W. Telephone: 202-305-3274

Dated: April 3, 2008

Attorneys for Defendant