Free Motion for Leave to Exceed Page Limit - District Court of Federal Claims - federal

Case 1:99-cv-00194-EGB

Document 113

Filed 08/27/2004

Page 1 of 3

IN THE UNITED STATES COURT OF FEDERAL CLAIMS ____________________________________ ) ) ) ) Plaintiff, ) ) ) ) THE UNITED STATES, ) ) Defendant. ) ____________________________________) MARKETING AND MANAGEMENT INFORMATION, INC.,

No. 99-194C (Judge Bruggink)

PLAINTIFF'S UNOPPOSED MOTION FOR EXTENSION OF PAGE LIMITATIONS FOR PLAINTIFF'S MEMORANDUM OF CONTENTIONS OF FACT AND LAW Pursuant to RCFC 5.2(B)(1), Plaintiff Marketing and Management Information, Inc. hereby respectfully moves for a 20-page extension of the 40-page limit otherwise applicable to Plaintiff's Memorandum of Contentions of Fact and Law ("Memorandum"). As grounds for this motion, Plaintiff states as follows: 1. According to RCFC 5.2.(B)(1), "[e]xcept by leave of the court on motion,

a party's initial brief or memorandum shall not exceed 40 pages." 2. In this case, several outstanding, discrete factual and legal issues remain to

be resolved by the Court, each of which warrants separate treatment in Plaintiff's Memorandum. In order to apprise both Defendant and the Court of its relevant contentions, Plaintiff has endeavored to clearly frame and meaningfully treat each such contention. 3. At the same time, Plaintiff has endeavored to be crisp and concise in its

treatment. Plaintiff has now come to the conclusion, however, that adequate treatment of

Case 1:99-cv-00194-EGB

Document 113

Filed 08/27/2004

Page 2 of 3

the relevant contentions will require substantially more than the 40 pages allotted by rule. As such, Plaintiff respectfully requests that it be granted 20 additional pages for purposes of the Memorandum, for a maximum of 60 pages, and pledges that it will strive to submit a Memorandum that is well under that limit. 4. motion. Wherefore, Plaintiff MMI respectfully requests that the Court grant a 20-page extension of the 40-page limit otherwise applicable to Plaintiff's Memorandum. Counsel for Defendant has indicated that Defendant will not object to this

August 27, 2004

Respectfully submitted,

/s/Charles J. Cooper_________________ CHARLES J. COOPER Cooper & Kirk, PLLC 1500 K Street, NW Suite 200 Washington, DC 20005 (202) 220-9600 Counsel of Record for Plaintiff Of Counsel: Vincent J. Colatriano Derek L. Shaffer Nikki Chtaini Cooper & Kirk, PLLC 1500 K Street, NW Suite 200 Washington, D.C. 20005

Case 1:99-cv-00194-EGB

Document 113

Filed 08/27/2004

Page 3 of 3