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

Case 1:05-cv-00448-NBF

Document 24

Filed 02/16/2006

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS RAYTHEON COMPANY, Plaintiff, v. UNITED STATES OF AMERICA, Defendant ) ) ) ) ) ) ) ) )

No. 05-448C (Judge Firestone)

DEFENDANT'S MOTION FOR ENLARGEMENT OF TIME Pursuant to RCFC 6(b) and 6.1, defendant, the United States, respectfully requests an enlargement of time of 11 days (to and including February 27, 2006) within which defendant may serve its initial written discovery requests. Absent the requested enlargement, defendant would be required to serve its initial written discovery requests no later than February 16, 2006. See Order on Joint Motion for Enlargement of Time, dated January 18, 2006. This is defendant's first separate request for an enlargement of time for this purpose, the Court having granted the parties' joint motion for an enlargement of 30 days in its January 18, 2006 Order. On February 15, 2006, undersigned counsel for defendant discussed this motion with Karen L. Manos, Esq., counsel for plaintiff, who stated that plaintiff would not oppose defendant's motion. The requested enlargement is needed in order to allow defendant an adequate opportunity to complete the preparation of defendant's initial written discovery requests. Because undersigned counsel for defendant was out of the office due to illness from February 7 through 13, it will not be possible to serve these requests by the current due date (February 16). The brief enlargement of time requested (11 days) will give defendant the opportunity to prepare and serve these initial discovery requests. Further, it does not appear that grant of the requested

Case 1:05-cv-00448-NBF

Document 24

Filed 02/16/2006

Page 2 of 3

enlargement would interfere with the parties' ability to file by March 17, 2006, their joint status report proposing a date for the close of discovery, as the Court directed in its January 18, 2006 Order. For the foregoing reasons, defendant respectfully requests that the Court enter an order granting the requested enlargement of time. Respectfully submitted, PETER D. KEISLER Assistant Attorney General

s/ David M. Cohen DAVID M. COHEN Director OF COUNSEL: LAWRENCE S. RABYNE Defense Contract Management Agency 1523 W. Central Road Arlington Heights, IL 60005-2451 Dated: February 16, 2006 s/ C. Coleman Bird C. COLEMAN BIRD Senior Trial Counsel Commercial Litigation Branch Civil Division Department of Justice 1100 L Street, N.W. Attn: Classification Unit 8th Floor Washington, D.C. 20530 Telephone: 202.307.0453 Facsimile: 202.514.7965 Attorneys for Defendant United States of America

Case 1:05-cv-00448-NBF

Document 24

Filed 02/16/2006

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CERTIFICATE OF FILING I hereby certify that on the 16th day of February, 2006, a copy of the foregoing Defendant's 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. Parties may access this filing through the Court's system. s/ C. Coleman Bird

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