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

Case 1:07-cv-00858-MBH

Document 24

Filed 05/16/2008

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS

THE CNA CORPORATION, Plaintiff, v.

THE UNITED STATES, Defendant.

) ) ) ) ) ) ) ) ) )

No. 07-858C (Judge Horn)

DEFENDANT'S CONSENT MOTION FOR AN ENLARGEMENT OF TIME WITHIN WHICH TO FILE ITS REPLY IN SUPPORT OF ITS MOTION TO STRIKE PLAINTIFF'S APPLICATION FOR BID PREPARATION AND PROPOSAL COSTS Defendant respectfully requests that this Court grant an enlargement of time of 7 days within which we may file our reply brief in support of our motion to strike plaintiff's application for bid preparation and proposal costs. Our reply currently is due on May 19, 2008. This is our first request for an enlargement of time for this purpose. Plaintiff consents to the instant motion. We require additional time to prepare and file our reply brief because undersigned counsel of record was hospitalized this past Wednesday and Thursday, May 14-15, 2008, and was occupied with other case-related work ­ including an oral argument before Judge Allegra in Lublin Corp. v. United States, Fed. Cl. No. 07-206 ­ earlier this week. Accordingly, we respectfully ask this Court to grant our request for an enlargement of time.

Respectfully submitted, GREGORY G. KATSAS Acting Assistant Attorney General JEANNE E. DAVIDSON Director

Case 1:07-cv-00858-MBH

Document 24

Filed 05/16/2008

Page 2 of 2

s/ Deborah A. Bynum by s/ B. Snee DEBORAH A. BYNUM Assistant Director s/ Matthew H. Solomson MATTHEW H. SOLOMSON Trial Attorney, Commercial Litigation Branch Civil Division, United States Department of Justice 1100 L Street, N.W. Washington, DC 20530 Tele: (202) 305-3274 Fax: (202) 514-8624 Dated: May 16, 2008 Attorneys for Defendant

-2-