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

Case 1:05-cv-00595-EJD

Document 21

Filed 12/13/2006

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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)

UNOPPOSED MOTION FOR ENLARGEMENT OF TIME Because of the unavailability of an important Government witness in this matter, we respectfully request a one-day enlargement to file our cross-motion for summary judgment and response to plaintiff's motion for summary judgment, until December 20, 2006. In accordance with the Court's August 30, 2006 scheduling order, this filing is presently due on December 19, 2006. This our first request for enlargement in this matter and plaintiff's counsel does not oppose it. We seek this enlargement because Mr. Joe Johnson, an important agency witness who may provide a declaration for our cross-motion and response, is unavailable for consultation this week due to his involvement in a GAO bid protest. We anticipate that he will be available for consultation early next week, allowing for a filing of our motion incorporating his information by December 20. Because the Court's scheduling order set forth dates for the parties' reply briefs, we respectfully request that they be extended an additional business day as well. Accordingly, plaintiff's response and reply would be due on January 22, 2007 and the Government's reply would be due on February 5, 2006.

Case 1:05-cv-00595-EJD

Document 21

Filed 12/13/2006

Page 2 of 2

Accordingly, we respectfully request that the Court grant this unopposed motion for enlargement of time. Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director

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

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 December 13, 2006

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