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

Case 1:06-cv-00099-LB

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Filed 06/17/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS INFORMATION SYSTEMS & NETWORKS CORPORATION, Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) )

No. 06-99C (Judge Block)

DEFENDANT'S CONSENT MOTION TO ENLARGE PERIOD TO RESPOND TO PLAINTIFF'S MOTION IN LIMINE Defendant, the United States, respectfully requests that the Court grant an enlargement of time of 14 days, to and including Monday, July 14, 2008, within which to respond to plaintiff's June 13, 2008 Motion In Limine. This is defendant's first At

request for an enlargement of time for this purpose.

plaintiff's request, we also request that the Court grant plaintiff until August 14, 2008, to reply to our response. Defendant's response to plaintiff's motion is due on June 30, 2008. We request the enlargement because lead counsel

for defendant will be out of the office from June 23 through July 4, 2008, including to appear in Portland, Oregon, for an oral argument on July 1, 2008, in White Buffalo Construction, Inc. v. United States, No. 99-961C (Fed. Cl.). Counsel for plaintiff has represented to counsel for defendant that plaintiff consents to this request. For the

foregoing reasons, the United States respectfully requests that the Court grant this consent motion for an enlargement of time of

Case 1:06-cv-00099-LB

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14 days, to July 14, 2008, to respond to plaintiff's Motion In Limine, and that the Court grant plaintiff until August 14, 2008, to reply to our responses. Respectfully submitted, GREGORY G. KATSAS Acting Assistant Attorney General JEANNE E. DAVIDSON Director

s/Mark A. Melnick by s/Brian M. Simkin MARK A. MELNICK Assistant Director

s/Timothy P. McIlmail TIMOTHY P. MCILMAIL Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L Street, N.W. Washington, D.C. 20530 Telephone: (202) 616-0342 Facsimile: (202) 514-7965 June 17, 2008 Attorneys for Defendant

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Case 1:06-cv-00099-LB

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CERTIFICATE OF FILING I hereby certify that on June 17, 2008, a copy of the foregoing DEFENDANT'S CONSENT MOTION TO ENLARGE PERIOD TO RESPOND TO PLAINTIFF'S MOTION IN LIMINE 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. may access this filing through the Court's system. Parties

s/Timothy P. McIlmail