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

Case 1:07-cv-00627-SGB

Document 27

Filed 03/19/2008

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS (BID PROTEST) SEALIFT, INC., Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) )

No. 07-627 (Judge Braden)

DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Pursuant to Rule 6(b) and 6.1 of the Rules of the United States Court of Federal Claims, defendant, the United States, respectfully requests a six-day enlargement of time, through and including March 25, 2008, within which to file its cross-motion and response to plaintiff's motion for judgment upon the administrative record. Currently, the Government's response is due March 19, 2008. This is defendant's second request for an enlargement of time for this purpose. The plaintiff, through its respective counsel, has been contacted regarding this request and does not oppose this motion so long as the plaintiff's response and reply deadline is also enlarged six days, to and including April 8, 2008. This enlargement is requested to provide the Government additional time to obtain the necessary approvals and review of the Government's response and cross-motion. Plaintiff's motion, proposed facts, and supporting brief altogether comprised more than 70 pages of briefing to which the Government must respond. This, along with the delay caused by Government counsel's unexpected illness, has resulted in the Government requiring a few additional days to complete and circulate its response and cross-motion for discussion and review among officials with the Navy and the Justice Department.

Case 1:07-cv-00627-SGB

Document 27

Filed 03/19/2008

Page 2 of 2

For these reasons, defendant respectfully requests that the Court grant this unopposed motion for an enlargement of time. Respectfully submitted, JEFFREY S. BUCHOLTZ Acting Assistant Attorney General JEANNE E. DAVIDSON Director s/Mark A. Melnick MARK A. MELNICK Assistant Director s/Marla T. Conneely MARLA T. CONNEELY Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit, 8th Floor 1100 L Street, N.W. Washington, D.C. 20530 Tel: (202) 305-3689 Fax: (202) 305-7643 March 19, 2008 Attorneys for Defendant

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