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

Case 1:06-cv-00312-TCW

Document 11

Filed 11/07/2006

Page 1 of 3

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 UNOPPOSED MOTION TO MODIFY THE DISCOVERY SCHEDULE Pursuant to Rules 6(b) and 6.1 of the Rules of the United States Court of Federal Claims ("RCFC"), the United States respectfully requests an enlargement of the deadline for serving the parties' RCFC 26 initial disclosures. The disclosures are currently due on November 13, 2006. The United States requests a seven day enlargement ­ making the disclosures due on November 20, 2006. The United States has not previously sought an enlargement of this deadline, and plaintiff consents. This modest extension is warranted because of time constraints faced by trial counsel and agency counsel for the United States. Specifically, the undersigned trial attorney has upcoming deadlines over the next two weeks that will make it difficult to complete the disclosures, including a brief due in this Court on November 9, 2006 in a bid protest and arguments in this Court on November 14, 2006 and before the Federal Circuit on November 8, 2006. Agency counsel has also requested additional time to complete his review of its documentary records and gather information regarding persons having information regarding this case. Accordingly, we respectfully request a seven day enlargement, making the parties' initial disclosures due on November 20, 2006.

Case 1:06-cv-00312-TCW

Document 11

Filed 11/07/2006

Page 2 of 3

Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director s/ Todd M. Hughes TODD M. HUGHES Assistant Director s/ Brian T. Edmunds BRIAN T. EDMUNDS Trial Attorney Commercial Litigation Branch Civil Division Department of Justice 1100 L Street, N.W. Attn: Classification Unit, 8th Floor Washington, DC 20530 Tel. (202) 353-0527 Fax. (202) 305-2118 November 7, 2006 Attorneys for Defendant

2

Case 1:06-cv-00312-TCW

Document 11

Filed 11/07/2006

Page 3 of 3

CERTIFICATE OF FILING I hereby certify that on November 7, 2006, a copy of the foregoing "DEFENDANT'S UNOPPOSED MOTION TO MODIFY THE DISCOVERY SCHEDULE" was filed electronically. Parties may access this filing through the Court's electronic filing system.

s/ Brian T. Edmunds

3