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

Case 1:05-cv-01029-MCW

Document 37

Filed 05/07/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS CALIFORNIA HUMAN DEVELOPMENT CORPORATION, Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) )

No. 05-1029C (Judge Williams)

DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Pursuant to Rule 6.1 of the Rules of the Court of Federal Claims, defendant, the United States, respectfully requests that the Court enlarge by 14 days, to and including May 23, 2008, the deadline for the meeting of counsel. Currently, the meeting of counsel is to be completed by May 9, 2008, pursuant to the Court's revised February 15, 2008 scheduling order. The United States is not requesting that any other deadlines in the Court's revised scheduling order be altered. On May 7, 2008, counsel for the Government spoke with counsel for California Human Development Corporation ("CHDC") regarding this request. Counsel for CHDC stated that CHDC would not oppose this request. On April 16, 2008, counsel for the Government was assigned a bid protest matter (entitled Great Lakes Dredge & Dock Company LLC v. United States, Case No. 08-282 (Fed. Cl.)) that is set on an expedited briefing schedule. Pursuant to the expedited briefing schedule, counsel for the Government was required to file the administrative record on April 25, 2008, and file a motion for summary judgment on the administrative record on May 5, 2008. In addition, counsel for the Government is required to file a response brief on May 9, 2008, and conduct oral argument on May 16, 2008.

Case 1:05-cv-01029-MCW

Document 37

Filed 05/07/2008

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In addition to the expedited briefing schedule in Great Lakes, during the week of April 28, 2008, counsel for the Government was required to file informal briefs in Kotschwar v. Office of Personnel Management, Case No. 2007-3244 (Fed. Cir.) and Lanzo v. Department of Veterans Affairs, Case No. 2008-7075 (Fed. Cir.). As a result, the Government needs additional time to prepare for and participate in the meeting of counsel. Granting this request for an enlargement should not cause any material inconvenience, prejudice, or delay. Accordingly, we respectfully request that this Court enlarge by 14 days, to and including May 23, 2008, the deadline for the meeting of counsel in this matter.

Respectfully submitted, GREGORY G. KATSAS Acting Assistant Attorney General JEANNE E. DAVIDSON Director s/ Bryant G. Snee BRYANT G. SNEE Deputy Director s/ Robert C. Bigler ROBERT C. BIGLER Trial Attorney Department of Justice Civil Division Commercial Litigation Branch 1100 L. Street, NW Attn: Classification Unit 8th Floor Washington, D.C. 20530 Tel: (202) 307-0315 Fax: (202) 514-8624 May 7, 2008 Attorneys for Defendant

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Case 1:05-cv-01029-MCW

Document 37

Filed 05/07/2008

Page 3 of 3

CERTIFICATE OF FILING I hereby certify that on this 7th day of May 2008, a copy of the foregoing "DEFENDANT'S UNOPPOSED 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 C. Bigler