Free Motion for Extension of Time to File Response/Reply - District Court of Federal Claims - federal

Case 1:01-cv-00570-MCW

Document 188

Filed 04/11/2008

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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 7-day enlargement of time, to and including April 25, 2008, to file its response to plaintiffs' cross-motion for summary judgment. Our response is currently due on April 18, 2007. Defendant further requests that the deadlines for the remaining brief, the parties' replies to the cross-motions for summary judgment, also be enlarged by 7 days. Therefore, the parties' replies to the cross-motions for summary judgment

Case 1:01-cv-00570-MCW

Document 188

Filed 04/11/2008

Page 2 of 4

would be due on May 23, 2008. 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 motion seeking additional time on February 11, 2008. Plaintiffs' counsel has stated that he does not oppose this motion, with the understanding that plaintiffs' deadlines would also be enlarged by 7 days. The enlargement is requested because the undersigned counsel of record for defendant requires additional time to respond to plaintiffs' 82-page summary judgment motion (which includes an appendix of 200 documents), and, once that is concluded, to complete briefing in this case. In addition, undersigned counsel for the defendant requests the additional time because of family medical matters which she needs to attend to during this time period. For the foregoing reasons, defendant respectfully requests that the Court grant its motion for an enlargement of time of 7 days, to and including April 25, 2008, within which to file defendant's cross-motion for summary judgment, and also to extend all deadlines in this matter by 7 days.

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Case 1:01-cv-00570-MCW

Document 188

Filed 04/11/2008

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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 11, 2008 Attorneys for Defendant

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Case 1:01-cv-00570-MCW

Document 188

Filed 04/11/2008

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Certificate of Filing I hereby certify that on this 11th 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