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

Case 1:08-cv-00444-ECH

Document 19

Filed 06/30/2008

Page 1 of 3

IN THE UNITED STATES COURT OF FEDERAL CLAIMS BID PROTEST WESTON SOLUTIONS, INC., ) ) Plaintiff, ) ) v. ) ) THE UNITED STATES, ) ) Defendant. ) ) and ) ) ECOLOGY AND ENVIRONMENT, INC. ) ) Defendant-Intervenor )

No. 08-444C (Judge Hewitt)

DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME Pursuant to Rule 6.1 of the Rules of this Court, defendant, the United States, respectfully requests a 7-hour enlargement of time within which to file the administrative record. Currently, the administrative record is due at 5 pm EDT on June 30, 2008. The extension would bring the date for filing the administrative record to midnight, July 1, 2008. This is the defendant's first request for an enlargement of time for this purpose. Counsel for plaintiff has indicated that plaintiff is not opposed to this motion and counsel for defendant-intervenor has indicated that defendant-intervenor is not opposed to this motion. This 7-hour request for enlargement is necessitated by the fact that the record is not prepared to be filed by 5 pm. While all of the documents for the record have been gathered electronically, they still need to be numbered, labeled with the protected information label,

Case 1:08-cv-00444-ECH

Document 19

Filed 06/30/2008

Page 2 of 3

broken into files under 4 megabytes to be filed electronically,1 and printed for the courtesy copy. Additionally, the paralegal that had been assisting in preparing the record has gone on vacation. Therefore, Government counsel had to find a new paralegal to accomplish these tasks today.2 The additional time requested is necessary to enable the Government to label, number and print the record, break several tabs into numerous four-megabyte files and file the record electronically. For these reasons, defendant respectfully requests that the Court grant defendant's unopposed motion for an enlargement of time of 7 hours, through and including midnight July 1, 2008, within which to file the administrative record. Respectfully submitted, GREGORY G. KATSAS Acting Assistant Attorney General JEANNE E. DAVIDSON Director /s/ Bryant G. Snee by Todd M. Hughes BRYANT G. SNEE Deputy Director

There are 47 tabs, consisting of well over 3,000 pages. Several of these tabs appear to be several times larger than four megabytes. Government counsel had anticipated that the record would be completed, with the exception of breaking down certain tabs into four megabyte files, before the paralegal left for vacation.
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Case 1:08-cv-00444-ECH

Document 19

Filed 06/30/2008

Page 3 of 3

June 30, 2008

/s/ William P. Rayel WILLIAM P. RAYEL Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L Street, N.W. Washington, D.C. 20005 Tel. (202) 616-0302 Fax. (202) 307-0972 Attorneys for Defendant