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

Case 1:93-cg-00648-SGB

Document 236

Filed 10/18/2007

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS __________________________________________ ) LAND GRANTORS IN HENDERSON, ) UNION, AND WEBSTER COUNTIES, et al., ) ) Plaintiffs, ) ) No. 93-648 X v. ) ) Judge Susan G. Braden UNITED STATES OF AMERICA, ) ) Defendant. ) __________________________________________) PLAINTIFFS' UNOPPOSED MOTION FOR ENLARGEMENT OF TIME Pursuant to RCFC 6.1, Plaintiffs submit this Unopposed Motion for Enlargement of Time to file its Response to the United States' Motion for Judgment on the Pleadings or, in the Alternative, Motion for Judgment on the Record, filed on October 1, 2007, in the abovecaptioned case. Plaintiffs respectfully ask to extend the deadline to file its Response by fortyfour (44) days, to and including December 14, 2007. Counsel for Plaintiffs has consulted with counsel for the government and is authorized to state that the government does not oppose the relief sought in this motion. Plaintiffs seek this enlargement of time because of deadlines in other pending cases. Specifically, counsel for Plaintiffs have another opposition to Summary Judgment already due in another case in this Court, have weeks of out-of-state depositions scheduled in two other cases, and must file two appellate briefs in the Federal Circuit in the next four to six weeks. Additionally, lead counsel for Plaintiffs was out of town for a week on previously scheduled speaking engagements at the CFC Judicial Conference earlier this month. Plaintiffs also seek this extension because this case requires coordination between various counsel and involves complex the issues.

Case 1:93-cg-00648-SGB

Document 236

Filed 10/18/2007

Page 2 of 2

For the reasons stated above, Plaintiffs request an enlargement of time, to and including December 14, 2007, to file its Response to the United States' Motion for Judgment on the Pleadings or, in the Alternative, Motion for Judgment on the Record. Respectfully submitted,

_/s/ Nancie G. Marzulla______ Nancie G. Marzulla Roger J. Marzulla MARZULLA & MARZULLA 1350 Connecticut Avenue, N.W. Suite 410 Washington, D.C. 20036 (202) 822-6760 (202) 822-6774 (facsimile) Dated: October 18, 2007 Counsel for Plaintiffs

Of counsel: M. Stephen Pitt Merrill S. Schell Jean W. Bird WYATT, TARRANT & COMBS, LLP 500 West Jefferson Street Suite 2800 Louisville, Kentucky 40202