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

Case 1:05-cv-00595-EJD

Document 9

Filed 10/14/2005

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS NORTHROP GRUMMAN INFORMATION TECHNOLOGY, INC. Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) )

No. 05-595C (Senior Judge Smith)

DEFENDANT'S SECOND UNOPPOSED MOTION FOR ENLARGEMENT Defendant respectfully requests an enlargement of time of 7calendar days, to and including October 21, 2005, for the parties to file their Joint Preliminary Status Report ("JPSR"). The JPSR is presently due October 14, 2005. This is our first request for an enlargement of time for this matter. Government counsel has discussed this motion with plaintiff's counsel and represents that plaintiff agrees that the requested enlargement of time is appropriate. The additional time is requested because counsel for the parties have been unable to adequately confer upon the contents of the JPSR. Government counsel has recently been assigned a bid protest, Alion Science & Technology, Corp. v. United States, No. 05-1072, which has absorbed substantially all of his time for the last week. Nevertheless, Government counsel is near ready to provide his suggested inputs for the JPSR and anticipates that it may be filed within the time requested. For the foregoing reasons, defendant respectfully requests that the Court grant this unopposed motion for an enlargement of time. Respectfully submitted, PETER D. KEISLER Assistant Attorney General

Case 1:05-cv-00595-EJD

Document 9

Filed 10/14/2005

Page 2 of 2

DAVID M. COHEN Director

s/Donald E. Kinner DONALD E. KINNER Assistant Director

OF COUNSEL: John T. Lauro Air Force Legal Services Agency 1501 Wilson Blvd. Arlington, VA 22209-2403

s/J. Reid Prouty J. REID PROUTY Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L Street, N.W. Washington, D.C. 20530 Tel: (202) 305-7586 Fax: (202) 514-7969 Attorneys for Defendant

October 14, 2005