GOOGLE, INC. et al v. USA

Filing 17

Joint MOTION to Amend Schedule, filed by GOOGLE, INC., ONIX NETWORKING CORPORATION, USA.Response due by 11/29/2010.(Krafchek, Christopher)

GOOGLE, INC. et al v. USA

Doc. 17

IN THE UNITED STATES COURT OF FEDERAL CLAIMS BID PROTEST ************************************* * GOOGLE, INC., et. al. * * Plaintiffs, * * v. * * THE UNITED STATES, * * Defendant. * * *************************************

No. 10-743C (Judge Braden)

JOINT MOTION TO MODIFY BRIEFING SCHEDULING Pursuant to Rules 6(b) and 6.1 of the Rules of the United States Court of Federal Claims ("RCFC"), defendant, the United States, and plaintiff, Google, Inc., respectfully request that the Court modify the current briefing schedule. This is the parties' first request for a modification for this purpose. The parties request that the briefing schedule be modified as follows: DATE November 5, 2010: November 19, 2010: EVENT Filing of the administrative record Government files opposition to Plaintiffs' motion for preliminary injunction Plaintiffs file consolidated reply to Government Opposition and motion for judgment upon the administrative record Government files cross-motion for judgment upon the administrative record and response Plaintiffs file response and reply Government files reply.

December 3, 2010:

December 17, 2010:

December 31 , 2010: January 11, 2010:

If granted by the Court, the modification of the briefing schedule will help ensure that the

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parties file quality briefs and these changes should not adversely impact the briefing schedule. The parties realize that they are not privy to the internal planning of the Court and hope this requested extension is not overly burdensome. The parties apologize for any inconvenience this may cause the Court. For the foregoing reasons, the parties respectfully request that the briefing schedule be enlarged by seven days, to and including November 19, 2010, to permit defendant to file its opposition to plaintiffs' motion for a preliminary injunction and permit plaintiffs to file a consolidated response to defendant's opposition and motion for judgment upon the administrative record on December 3, 2010. Respectfully submitted, TONY WEST Assistant Attorney General MICHAEL F. HERTZ Deputy Assistant Attorney General s/ Kirk T. Manhardt KIRK T. MANHARDT Assistant Director OF COUNSEL CHARLES M. KERSTEN Trial Attorney Commercial Litigation Branch Civil Division Department of Justice SHERYL RAKESTRAW Attorney Advisor Department of the Interior November 10, 2010 s/ Christopher L. Krafchek CHRISTOPHER L. KRAFCHEK Trial Attorney Commercial Litigation Branch Civil Division Department of Justice 1100 L Street, N.W. Washington, D.C. 20005 Tel: [phone] Fax: [phone] Attorneys for Defendant

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CERTIFICATE OF FILING I hereby certify that on this 10th day of November, 2010, a copy of the foregoing "JOINT MOTION TO MODIFY THE BRIEFING SCHEDULING" was filed electronically. I understand that notice of this filing will be sent to all parties by operation of the Court's electronic filing system. Parties may access this filing through the Court's system. s/Christopher L. Krafchek