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

Case 1:06-cv-00312-TCW

Document 19

Filed 11/28/2007

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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)

AMENDED MOTION FOR AN ENLARGEMENT OF TIME TO RESPOND TO PLAINTIFF'S MOTION FOR PARTIAL SUMMARY JUDGMENT Pursuant to Rule 6(b) of the Rules of the United States Court of Federal Claims, we respectfully request that this Court enlarge our deadline for responding to plaintiff's motion for partial summary judgment to a date 14 days after this Court issues an order, if any, denying our Rule 56(f) motion of November 19, 2007. We filed the Rule 56(f) motion, and in the alternative sought a 14-day enlargement of time for responding, through and including December 5, 2007, which was not adequate to enable plaintiff to respond to, or the Court to rule upon, our motion. Realizing that plaintiff's response to our Rule 56(f) motion is due on December 6, 2007, and that the Court will need time to rule on the motion, we respectfully withdraw our previous alternative motion for a 14-day enlargement through December 5, 2007 and respectfully request, instead, that if the Court does not grant our Rule 56(f) motion, the Court order our response to plaintiff's partial motion for summary judgment to be filed within 14 days of an order denying our Rule 56(f) motion. Plaintiff consents to this request. Respectfully submitted, JEFFREY S. BUCHOLTZ Acting Assistant Attorney General

Case 1:06-cv-00312-TCW

Document 19

Filed 11/28/2007

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JEANNE E. DAVIDSON Director s/ Martin F. Hockey, Jr. MARTIN F. HOCKEY, JR. Assistant Director 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 November 28, 2007 Attorneys for the United States

Case 1:06-cv-00312-TCW

Document 19

Filed 11/28/2007

Page 3 of 3

CERTIFICATE OF FILING I hereby certify that on November 28, 2007, a copy of the foregoing "AMENDED MOTION FOR AN ENLARGEMENT OF TIME TO RESPOND TO PLAINTIFF'S MOTION FOR PARTIAL SUMMARY JUDGMENT" together with the supporting declaration, was filed electronically. Parties may access this filing through the Court's electronic filing system.

s/ Brian T. Edmunds