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

Case 1:05-cv-00448-NBF

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Filed 01/13/2006

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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)

JOINT MOTION FOR ENLARGEMENT OF TIME Pursuant to RCFC 6(b) and 6.1, plaintiff, Raytheon Company, and defendant, the United States, jointly and respectfully request an enlargement of time of 30 days (to and including February 16, 2006) within which each party may serve its initial written discovery requests. Absent the requested enlargement, the parties would be required to serve their initial written discovery requests no later than January 17, 2006. See Scheduling Order dated October 28, 2005. This is the parties' first request for an enlargement of time for this purpose. The requested enlargement is needed in order to allow the parties an adequate opportunity to prepare their initial written discovery requests. Due to the requirements of other cases pending before this court, neither party will be able to complete the preparation of its initial written discovery requests by the current due date (January 17). Further, it does not appear that grant of the requested enlargement would interfere with the parties' ability to file a joint status report by March 17, 2006, proposing a date for the close of discovery, as required by the Court's October 28 Scheduling Order. For the foregoing reasons, the parties respectfully request that the Court enter an order granting the requested enlargement of time.

Case 1:05-cv-00448-NBF

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Filed 01/13/2006

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Respectfully submitted, s/ Karen L. Manos KAREN L. MANOS Howrey LLP 1299 Pennsylvania Avenue, N.W. Washington, D.C. 20004 Telephone: 202.383.7472 Facsimile: 202.383.6610 Attorney for Plaintiff Raytheon Company Dated: January 13, 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 OF COUNSEL: LAWRENCE S. RABYNE Defense Contract Management Agency 1523 W. Central Road Arlington Heights, IL 60005-2451 PETER D. KEISLER Assistant Attorney General

s/ David M. Cohen DAVID M. COHEN Director

Case 1:05-cv-00448-NBF

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Filed 01/13/2006

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CERTIFICATE OF FILING I hereby certify that on the 13th day of January, 2006, a copy of the foregoing Joint 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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