GOOGLE, INC. et al v. USA

Filing 93

Unopposed MOTION for Extension of Time until June 15, 2011 to to file reply, filed by USA.Response due by 6/27/2011.(Krafchek, Christopher)

IN THE UNITED STATES COURT OF FEDERAL CLAIMS
BID PROTEST
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GOOGLE, INC.,
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Plaintiff,
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and
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ONIX NETWORKING CORPORATION, *
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Plaintiff,
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v.
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THE UNITED STATES,
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Defendant,
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and,
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SOFTCHOICE CORPORATION,
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Defendant-Intervenor.
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No. 10-743C
(Judge Susan G. Braden)

UNOPPOSED MOTION TO ENLARGE
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 five-day enlargement of time, through and
including June 15, 2011, within which to file its reply in support of our cross motion for
judgment upon the administrative record and response to plaintiffs’ restated motion for judgment
on the refiled and updated administrative record (“reply”). Currently, our reply is due on June
10, 2011. This is defendant’s first request for an enlargement of time for this purpose. Plaintiffs
and defendant-intervenor do not object to this motion for an enlargement of time. This
enlargement is requested to provide the defendant sufficient time to respond to plaintiffs’ revised

motion, which raises significant and complex legal arguments, and to permit sufficient time for
supervisory review. Moreover, good cause exists for this request to enlarge the date upon which
a reply to plaintiffs’ opposition because undersigned counsel is actively litigating another bid
protest, Three S Consulting v. United States, Fed. Cl. No. 10-583, before this Court and an
appeal before United States Court of Appeals for the Federal Circuit, Mojarro v. United States,
Fed. Cir. No. 2011-3079. Additionally, undersigned counsel has been dealing with personal
matters that have only recently been fully resolved. Accordingly, although counsel for defendant
has worked diligently on this matter, additional time is required to complete defendant’s reply
brief.
Defendant apologizes for any inconvenience this may cause the Court.
For the foregoing reasons, defendant respectfully requests a five-day enlargement of time,
through and including June 15, 2011, within which to file our reply to plaintiffs’ revised motion.
Respectfully submitted,
TONY WEST
Assistant Attorney General
MICHAEL F. HERTZ
Deputy Assistant Attorney General

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s/ Kirk T. Manhardt
KIRK T. MANHARDT
Assistant Director
OF COUNSEL
SHERYL RAKESTRAW
Attorney Advisor
Department of the Interior

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]

June 9, 2011

Attorneys for Defendant

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