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

Case 1:06-cv-00157-FMA

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Filed 03/16/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS YATES INTERNATIONAL, L.L.C. COFC No. 06-157C Plaintiff, v UNITED STATES OF AMERICA, Defendant. __________________________________________

PLAINTIFF'S AMENDED UNAPPOSED MOTION FOR ENLARGEMENT OF TIME Yates International, L.L.C. ("Yates International"), by counsel, moves this Court for an enlargement of time of seven days, until March 27, 2007, to answer and object to the defendant's Interrogatories and Requests for Production of Documents. Plaintiff's counsel has discussed this motion with counsel for the defendant and counsel for the defendant does not oppose this request. In support of this Motion, Yates International states as follows: 1. The time for the plaintiff's response to the defendant's Interrogatories and

Requests for Production of Documents has not been enlarged previously. 2. The plaintiff is processing a large number of paper documents by electronic

means that will allow the plaintiff to produce the documents in an electronic format that will be beneficial to all parties. 3. Although the plaintiff began this process before defendant's requests were

received, the plaintiff has encountered technical problems that have delayed the processing and review of the documents. 4. The plaintiff's inability to access documents that are being processed delays the 1

Case 1:06-cv-00157-FMA

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plaintiff's ability to respond to the defendant's Interrogatories as well as its Requests for Production. 5. necessary. For the foregoing reasons, Yates International moves this Court to issue an order for an enlargement of time for the plaintiff to answer and object to the defendant's Interrogatories and Requests for Production of Documents and for such other relief as this Court may deem necessary and appropriate. Dated: March 16, 2007 The plaintiff is confident that an additional enlargement of time will not be

Respectfully submitted,

s/ Robert E. Korroch Williams Mullen Fountain Plaza Three, Suite 200 721 Lakefront Commons Newport News, Virginia 23606 [email protected] 757.249.5100 (telephone) 757.249.5109 (facsimile) Attorneys for Plaintiff

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Case 1:06-cv-00157-FMA

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CERTIFICATE OF FILING I hereby certify that on March 16, 2007, a copy of the foregoing "PLAINTIFF'S UNAPPOSED MOTION FOR ENLARGEMENT OF TIME was filed electronically. I understand that notice of this filing will be sent to all parties by operation of the Court's electronic filing system. Parties may access this filing through the Court's system.

s/ Robert E. Korroch

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