Free Motion for Extension of Time to File Response/Reply - District Court of Federal Claims - federal

Case 1:08-cv-00304-SGB

Document 8

Filed 06/20/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS INFORMATION SCIENCES CORP., Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) )

No. 08-304C (Judge Braden)

DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Defendant respectfully requests an enlargement of time of 30 days, to and including July 23, 2008, within which to file its response to plaintiff's complaint. Defendant's response is currently due to be filed June 23, 2008. This is defendant's first request for an enlargement of time. Counsel for plaintiff has represented that plaintiff does not oppose this request. An enlargement of time is necessary given the complexity of issues presented, coordination with agency counsel, and the volume of motions and briefs for other cases currently pending before this Court, the Court of Federal Claims, the Court of International Trade, and the London Court of International Arbitration assigned to undersigned counsel. The complaint in this case was filed on April 22, 2008. The undersigned is lead counsel in Amber Resources v. United States, No. 02-30, a portion of which went to trial from December 3 to 7, 2007 and January 7 to 11, 2008. The Government's 190-page post-trial brief was filed on May 16, 2008, and oral argument was held on June 9, 2008. Also since April 22, the undersigned has filed briefs in several cases, including Bouchard v. Department of Veterans Affairs (Fed. Cir. No. 2008-3067), Recino v. United States Postal Service (Fed. Cir. No. 2008-3102), Brodgon v. Office of Personnel Management (Fed. Cir. No. 2008-3195), Brantley v. Department of the Treasury (Fed. Cir. No. 2008-3219), and United States v. Canada (LCIA No. 7941). The

Case 1:08-cv-00304-SGB

Document 8

Filed 06/20/2008

Page 2 of 2

undersigned also will be conducting numerous depositions in June and July 2008 in the cases of Catel, Inc. v. United States (Ct. Fed. Cl. No. 05-1113) and United States v. Jackpine Forest Products Ltd. (CIT No. 06-00009). Additional time is necessary so that defendant's counsel may review the documents related to the challenged procurement and obtain any additional information or clarification from agency counsel and contracting personnel. For these reasons, defendant respectfully requests that the Court grant its unopposed motion for an enlargement of time. Respectfully submitted, GREGORY G. KATSAS Acting Assistant Attorney General JEANNE E. DAVIDSON Director

s/ Bryant G. Snee BRYANT G. SNEE Deputy Director

s/ Gregg M. Schwind GREGG M. SCHWIND Trial Attorney Commercial Litigation Branch Civil Division U.S. Department of Justice Attn: Classification Unit 8th Floor 1100 L Street, N.W. Washington D.C. 20530 Tel: (202) 353-2345 Fax: (202) 514-8624 June 20, 2008 Attorneys for Defendant

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