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

Case 1:05-cv-00595-EJD

Document 7

Filed 09/23/2005

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 UNOPPOSED MOTION FOR ENLARGEMENT Defendant respectfully requests an enlargement of time of 21calendar days, to and including October 15, 2005, for the parties to file their Joint Preliminary Status Report ("JPSR"). The JPSR is presently due September 23, 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 was in Alaska the prior week defending depositions while plaintiff's counsel has been in depositions and unavailable to confer upon the JPSR all of this week. Government counsel will be away from the office taking depositions all of the coming week. 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 7

Filed 09/23/2005

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

September 23, 2005