GOOGLE, INC. et al v. USA

Filing 70

Unopposed MOTION for Extension of Time to File Reply to Plaintiffs' Response to Softchoice's Motion to Terminate the Stay of Proceedings, Dissolve the Courts Preliminary Injunction, and Dismiss the Action, filed by SOFTCHOICE CORPORATION.Response due by 5/2/2011.(Rosenbaum, Steven)

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Electronically Filed on April 14, 2011 IN THE UNITED STATES COURT OF FEDERAL CLAIMS Bid Protest ____________________________________ GOOGLE, INC, ) ) and ) ) ONIX NETWORKING CORPORATION, ) ) Plaintiffs, ) ) v. ) ) UNITED STATES OF AMERICA, ) ) Defendant, ) ) SOFTCHOICE CORPORATION, ) ) Defendant-Intervenor. ) ) Case No. 10-743C Judge Susan G. Braden SOFTCHOICE CORPORATION’S UNOPPOSED MOTION TO ENLARGE Pursuant to Rules 6(b) and 6.1 of the Rules of the U.S. Court of Federal Claims, Defendant-Intervenor Softchoice Corporation (“Softchoice”) respectfully requests a five-day enlargement of time, through and including April 22, 2011, within which to file its reply to Plaintiffs’ Response to Softchoice’s Motion to Terminate the Stay of Proceedings, Dissolve the Court’s Preliminary Injunction, and Dismiss the Action (“Plaintiffs’ Opposition”). Currently, Softchoice’s reply to Plaintiffs’ Opposition is due on April 18, 2011.1 This is Softchoice’s first request for an enlargement of time in this case, and counsel for Plaintiffs and the Government do 1 The Government’s reply to Plaintiff’s Opposition also is due on April 18, 2011. On April 13, 2011, the Government filed an unopposed motion to extend the deadline for it to file a reply to the Plaintiffs’ Opposition to April 22, 2011. The Government’s motion incorrectly states that its reply is currently due on April 15, 2011. DC: 3950833-1 not oppose this request. This enlargement is requested to provide Softchoice with sufficient time to respond to Plaintiffs’ Opposition, which raises several legal arguments. In addition, this enlargement is requested to preserve the current briefing arrangement, with the Government and Softchoice filing replies to Plaintiffs’ Opposition on the same day. WHEREFORE, Softchoice respectfully requests a five-day enlargement of time, through and including April 22, 2011, within which to file our reply to Plaintiffs’ Opposition. Respectfully submitted, s/ Steven J. Rosenbaum Steven J. Rosenbaum Counsel of Record Alan A. Pemberton Sarah L. Wilson Scott A. Freling Shelli L. Calland COVINGTON & BURLING LLP 1201 Pennsylvania Avenue, N.W. Washington, D.C. 20004 Tel: (202) 662-5568 Fax: (202) 778-5568 srosenbaum@cov.com William A. Shook SHOOK DORAN KOEHL LLP 643 E Street, N.E. Washington, D.C. 20002 Tel: (202) 583-0008 Fax: (202) 280-1097 bill.shook@sdklaw.net April 14, 2011 Counsel for Softchoice Corporation -2-

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