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

Case 1:05-cv-00281-NBF

Document 19

Filed 10/11/2005

Page 1 of 3

IN THE UNITED STATES COURT OF FEDERAL CLAIMS ) ) Plaintiff, ) ) v. ) ) ) THE UNITED STATES, ) ) Defendant. ) __________________________________________) UNISYS CORPORATION,

No. 05-281C (Judge Firestone)

JOINT MOTION FOR ENLARGEMENT OF TIME Pursuant to RCFC 6(b) and 6.1, plaintiff, Unisys Corporation, and defendant, the United States, jointly and respectfully request an enlargement of time of 14 days (to and including October 25, 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 October 11, 2005. See Order dated September 26, 2005. This is the parties' second request for an enlargement of time for this purpose, the Court having granted the first request (for 21 days) in its September 26 Order. The requested enlargement is needed in order to allow the parties an additional opportunity to discuss and explore further plaintiff's suggestion that the issues in this case may be amenable to resolution upon motion for summary judgment, in whole or in substantial part. Plaintiff has prepared a draft of a joint motion that would propose such a procedure for the Court's consideration. The parties are discussing, and attempting to agree upon, the language for the proposed joint motion that would identify issues that appear appropriate for resolution by summary judgment and propose a procedure for their resolution that the parties could jointly

Case 1:05-cv-00281-NBF

Document 19

Filed 10/11/2005

Page 2 of 3

recommend for the Court's consideration. The additional time the parties have requested is needed in order for the parties to negotiate an agreement. For the foregoing reasons, the parties respectfully request that the Court enter an order granting the requested enlargement of time. Respectfully submitted, s/ Terry L. Albertson TERRY L. ALBERTSON Crowell & Moring LLP 1001 Pennsylvania Avenue, N.W. Washington, D.C. 20004-2595 Telephone: 202.624.2635 Facsimile: 202.628.5116 Attorney for Plaintiff Unisys Corporation Dated: October 11, 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

-2-

Case 1:05-cv-00281-NBF

Document 19

Filed 10/11/2005

Page 3 of 3

CERTIFICATE OF FILING I hereby certify that on the 11th day of October, 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