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

Case 1:05-cv-00945-EGB

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS OGDEN SUPPORT SERVICES, INC., et al., Plaintiffs, vs. UNITED STATES OF AMERICA, Defendant. ) ) ) ) ) ) ) ) )

No. 05-945C (Senior Judge Bruggink)

DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME Pursuant to Rule 6.1 of the Rules of the United States Court of Federal Claims, defendant, the United States, respectfully requests an enlargement of time of ten (10) business days, to and including July 31, 2006, to respond to plaintiffs' first set of interrogatories and first set of requests for protection of documents ("plaintiffs' discovery requests"). Defendant's responses to plaintiffs' discovery requests currently are due July 17, 2006, and this is defendant's first request for an enlargement of time to respond to plaintiffs' discovery requests. Defendant's counsel has conferred with plaintiffs' counsel regarding this motion, and plaintiffs' counsel stated that the motion would not be opposed by plaintiffs. This case involves factual assertions regarding contracts between plaintiff Ogden Support Services, Inc. and the Central Intelligence Agence ("CIA") entered into and performed during the 1980s and 1990s. See, e.g., Complaint ¶ 7. Plaintiffs' discovery requests seek information regarding factual issues dating back for as long as two decades. By necessity, the process of locating relevant records and living witnesses with recollection of the issues presented in the discovery requests has been and continues to be time-consuming. In addition, because many of the relevant documents maintained by the CIA are classified and nonpublic, the CIA has -1-

Case 1:05-cv-00945-EGB

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undertaken the process of declassifying materials for plaintiffs' review. See Joint Preliminary Status Report at 3 (Question (l) response). The process of declassifying documents has been time-consuming and is still ongoing. For the foregoing reasons, defendant respectfully requests that its unopposed motion for enlargement of time of ten (10) business days, to and including July 31, 2006, to respond to plaintiffs' first set of interrogatories and first set of requests for protection of documents be allowed. Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director /s/ Bryant G. Snee BRYANT G. SNEE Assistant Director

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/s/ John Warshawsky JOHN WARSHAWSKY 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) 307-0010 Facsimile: (202) 514-9163 Attorneys for Defendant July 17, 2006

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CERTIFICATE OF SERVICE I hereby certify that on July 17, 2006, a copy of 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 and that parties may access this filing through the Court's system.

/s/ John Warshawsky _______________________