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

Case 1:05-cv-00448-NBF

Document 15

Filed 09/26/2005

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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, respectfully request an enlargement of time of 15 days (to and including October 11, 2005) within which they may submit their Joint Preliminary Status Report. Absent the requested enlargement, the parties' Joint Preliminary Status Report would be due on or before September 26, 2005. RCFC Appendix A, ¶ 4. 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 discuss the contents of their Joint Preliminary Status Report, and prepare a Joint Preliminary Status Report that would be of assistance to the Court in determining the course of future proceedings in this case. Unfortunately, due to the requirements of other cases pending in this Court, the parties have not been able to complete the preparation of their Joint Preliminary Status Report by the current due date (September 26, 2005). 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

Document 15

Filed 09/26/2005

Page 2 of 3

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: September 26, 2005 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: STEPHEN R. DOOLEY Supervisory Trial Attorney Defense Contract Management Agency 495 Summer Street Boston, MA 02210 PETER D. KEISLER Assistant Attorney General

s/ David M. Cohen DAVID M. COHEN Director

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Case 1:05-cv-00448-NBF

Document 15

Filed 09/26/2005

Page 3 of 3

CERTIFICATE OF FILING I hereby certify that on the 26th day of September, 2005, 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