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

Case 1:05-cv-00463-LAS

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Filed 11/28/2005

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS GOVERNMENT TELECOMMUNICATIONS, INC., Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) No. 05-463C ) (Senior Judge Smith) ) ) )

DEFENDANT'S MOTION FOR AN ENLARGEMENT OF TIME, UPON BEHALF OF BOTH PARTIES Defendant, upon behalf of both parties, respectfully requests an enlargement of time of 15 calendar days, to and including December 13, 2005, within which to exchange initial disclosures in accordance with Rule 26(a)(1) of the Rules of the United States Court of Federal Claims ("RCFC"). The parties' This

initial disclosures are currently due on November 28, 2005.

is either party's first request for an enlargement of time for this purpose. Counsel for defendant has contacted counsel for

plaintiff regarding this motion; he has stated that plaintiff concurs in this motion. The additional time is necessary because, although the parties have begun to compile documents in order to comply with the initial disclosure required by the Court's rules, they have not completed their document compilation. Counsel for both

parties expect that the additional time will be sufficient within which to complete their compilation of documents, and delivery of those documents to opposing counsel. Thus, the additional time

Case 1:05-cv-00463-LAS

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is necessary within which to comply with RCFC 26(a)(1). For the foregoing reason, we respectfully request that our motion for an enlargement of time, upon behalf of both parties, be granted. Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director s/ Harold D. Lester, Jr. HAROLD D. LESTER, JR. Assistant Director s/ Lauren S. Moore LAUREN S. MOORE Attorney Commercial Litigation Branch Civil Division Department of Justice 1100 L Street, N.W. Attn: Classification Unit 8th Floor Washington, D.C. 20530 Tele: (202) 307-6288 Fax: (202) 514-8640 Attorneys for Defendant NOVEMBER 28, 2005

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Case 1:05-cv-00463-LAS

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CERTIFICATE OF FILING I hereby certify that on the 28th day of NOVEMBER, 2005, a copy of the foregoing "DEFENDANT'S MOTION FOR AN ENLARGEMENT OF TIME, UPON BEHALF OF BOTH PARTIES" 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 the parties may access this filing through the Court's system. /s/ Lauren S. Moore