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


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Case 1:06-cv-00282-MBH

Document 46

Filed 07/07/2006

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS [Bid Protest]

CHANT ENGINEERING, INC., Plaintiff, vs. UNITED STATES OF AMERICA, DEPARTMENT OF THE ARMY, and Defendant. No. 1:06-CV-00282 Assigned to Hon. Marian Blank Horn

DAYTON T. BROWN, INC., Intervenor.

INTERVENOR'S MOTION FOR ENLARGEMENT

Dale H. Oliver Jon Corey Rachel Fiset QUINN EMANUEL URQUHART OLIVER & HEDGES, LLP 865 South Figueroa Street, 10th Floor Los Angeles, California 90017 Telephone: (213) 443-3000 Facsimile: (213) 443-3100 Attorneys for Third-Party Intervenor Dayton T. Brown, Inc.

08888/1914341.1

Case 1:06-cv-00282-MBH

Document 46

Filed 07/07/2006

Page 2 of 2

Pursuant to Rule 6(b) and 6.1 of the Rules of the United States Court of Federal Claims, intervenor Dayton T. Brown respectfully requests a 1-day enlargement of time, through and including July 10, 2006, within which to file its Reply to Plaintiff's Response to Intervenor's Supplemental Brief. Intervenor's reply is currently due July 7, 2006. This is Intervenor's first request for an enlargement of time in this matter. The requested enlargement of time is necessary to afford Intervenor time to adequately respond to Plaintiff's Supplemental Brief. The Fourth of July holiday (and the preceding Monday) deprived Intervenor's counsel of two business days in which to consider Plaintiff's Supplemental Brief and to discuss technical issues raised in that brief with Intervenor's technical staff. Intervenor's counsel seeks one additional court day to discuss these issues with Intervenor's representatives and to provide the Court with a brief that completely addresses the issues raised in Plaintiff's brief. Accordingly, Intervenor respectfully requests that this motion for enlargement of time be granted. DATED: July 7, 2006 QUINN EMANUEL URQUHART OLIVER & HEDGES, LLP

By s/Dale H. Oliver Dale H. Oliver Attorneys for Intervenor Dayton T. Brown, Inc.

08888/1914341.1

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