Free Reply to Response to Motion - District Court of Federal Claims - federal

Case 1:06-cv-00312-TCW

Document 25

Filed 01/11/2008

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

No. 06-312C (Judge Wheeler)

UNITED STATES' REPLY IN SUPPORT OF MOTION TO ENLARGE DISCOVERY PERIOD The Court has already granted our motion and we therefore do not wish to burden the Court with disputes about who said or did what. However, rather than not reply at all to plaintiff's response, we deem the better course to be to provide this short reply informing the Court that we made no "misrepresentations" in our motion and can fully explain ­ with at least partial documentation ­ the events and circumstances leading to the need for an enlargement and the fact that we took action to schedule depositions before December 7, 2007. We will be happy to submit such an extended reply, if the Court wishes for us to do so. Respectfully submitted, JEFFREY S. BUCHOLTZ Acting Assistant Attorney General JEANNE E. DAVIDSON Director s/ Martin F. Hockey, Jr. MARTIN F. HOCKEY, JR. Assistant Director

Case 1:06-cv-00312-TCW

Document 25

Filed 01/11/2008

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s/ Brian T. Edmunds BRIAN T. EDMUNDS Trial Attorney Commercial Litigation Branch Civil Division Department of Justice 1100 L Street, NW Attn: Classification Unit, 8th Floor Washington, DC 20530 (202) 616-8253 January 11, 2008 Attorneys for the United States

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Case 1:06-cv-00312-TCW

Document 25

Filed 01/11/2008

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CERTIFICATE OF FILING I hereby certify that on this 11th day of January 2008, a copy of the foregoing "UNITED STATES REPLY IN SUPPORT OF MOTION TO ENLARGE DISCOVERY PERIOD" was filed electronically. Parties may access the filing through the Court's electronic filing system.

s/ Brian T. Edmunds

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