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

Case 1:05-cv-00281-NBF

Document 46

Filed 09/13/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS UNISYS CORPORATION, Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) )

No. 05-281C (Judge Firestone)

AMICUS DIRECTV GROUP, INC.'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME

Pursuant to RCFC 6(b) and 6.1, amicus DIRECTV Group, Inc. respectfully requests an enlargement of four days (to and including September 21, 2007) of the time within which DIRECTV may file its amicus brief reply in connection with the parties' cross-motions for summary judgment on the "surplus transfer" issue in the above-entitled proceedings. Absent the requested enlargement, DIRECTV would be required to file its reply on or before September 17, 2007. See Order dated August 17, 2007. This is DIRECTV's first request for an enlargement of time for this purpose. DIRECTV seeks this brief four-day enlargement of time for the filing of its amicus brief due to a family medical emergency of its counsel, which has delayed the completion of DIRECTV's amicus brief. Therefore, good cause exists for this request. On September 13, 2007, counsel for DIRECTV left a voice mail message for Coleman Bird, Esq., counsel for defendant United States, describing this motion, who responded that defendant would 1

Case 1:05-cv-00281-NBF

Document 46

Filed 09/13/2007

Page 2 of 2

not oppose the motion. Counsel for Unisys Corporation and General Electric Company have likewise advised that they do not oppose this Motion.

Respectfully submitted,

OF COUNSEL: Alan C. Brown Enterprise Business Law Group LLC 8405 Greensboro Drive, Suite 210 McLean, Virginia 22102 (703) 584-3250 (703) 848-8333 (fax)

_____/s/ Alexander F. Wiles Alexander F. Wiles IRELL & MANELLA LLP 1800 Avenue of the Stars, Suite 900 Los Angeles, CA 90067 (310) 277-1010 (310) 203-7199 (fax) Attorney of Record for THE DIRECTV GROUP, INC.

Dated: September 13, 2007

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