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

Case 1:01-cv-00570-MCW

Document 192

Filed 04/29/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS BLUE LAKE FOREST PRODUCTS, INC., ) ) Plaintiff, ) ) v. ) ) THE UNITED STATES, ) ) Defendant. ) TIMBER PRODUCTS COMPANY, Plaintiff, v. THE UNITED STATES, Defendant. CLR TIMBER HOLDINGS, INC., Plaintiff, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

No. 01-570C (Judge Williams)

No. 01-627C (Judge Williams)

No. 04-501C (Judge Williams)

DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Pursuant to Rules 6(b) and 6.1 of the Rules of the United States Court of Federal Claims ("RCFC"), defendant, the United States, respectfully requests a two-day enlargement of time, to and including May 2, 2008, to file its response to plaintiffs' cross-motion for summary judgment. Our response is currently due on April 30, 2007. The parties filed a Joint Status Report on January 3, 2008, requesting changes in the Court's September 28, 2007 scheduling order, and counsel for defendant filed an unopposed motions seeking additional time on February 11, 2008,

Case 1:01-cv-00570-MCW

Document 192

Filed 04/29/2008

Page 2 of 4

April 11, 2008, and April 23, 2008. Plaintiffs counsel has stated that he does not oppose this motion. We apologize for this last-minute request, however, we respectfully request this brief enlargement because undersigned counsel of record must incorporate supervisory and agency comments into the brief. Accordingly, defendant does not intend to seek any further enlargements for this purpose. For this reason, defendant respectfully requests that the Court grant its motion for an enlargement of time of two (2) days, to and including May 2, 2008, for the parties to file responses to the cross-motions for partial summary judgment.

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Case 1:01-cv-00570-MCW

Document 192

Filed 04/29/2008

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Respectfully submitted,

JEFFREY S. BUCHOLTZ Acting Assistant Attorney General JEANNE E. DAVIDSON Director

s/Bryant G. Snee BRYANT G. SNEE Deputy Director

s/Ellen M. Lynch ELLEN M. LYNCH Trial Attorney Commercial Litigation Branch Civil Division U.S. Department of Justice Attn: Classification Unit 1100 L Street, N.W., 8th Floor Washington, D.C. 20530 Tel: (202) 353-7994 Fax: (202) 514-8624 April 29, 2008 Attorneys for Defendant

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Case 1:01-cv-00570-MCW

Document 192

Filed 04/29/2008

Page 4 of 4

Certificate of Filing I hereby certify that on this 29th day of April, 2008, a copy of "Defendant's Unopposed Motion For An Enlargement Of Time" 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/Ellen M. Lynch Ellen M. Lynch