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

Case 1:91-cv-00984-EGB

Document 12

Filed 10/10/2003

Page 1 of 3

IN THE UNITED STATES COURT OF FEDERAL CLAIMS MANKE LUMBER CO., et al. (Mt. Adams Veneer Co.), Plaintiffs, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) )

Consolidated under lead case No. 33-85C (No. 91-984C) (Judge Bruggink)

UNOPPOSED MOTION FOR ENLARGEMENT OF TIME TO FILE RESPONSIVE BRIEF AND CROSS-MOTION Plaintiff Mt. Adams Veneer Co. moves the Court for an order enlarging time to respond to Defendant's Motion for Summary Judgment in Mt. Adams Veneer Co. v. United States, No. 91-984C. The response and cross-motion is presently due on October 14, 2003. The attorney for Plaintiff primarily responsible for preparation of the response and crossmotion has been out of the office on personal matters and other time conflicts have arisen which require additional time for completion and final review of the brief, declarations, and crossmotion. For the foregoing reasons, Plaintiff respectfully requests that its motion be granted, and that the time for filing of its reply and cross-motion to Defendant's Motion for Summary Judgment be enlarged to and including 60 days December 15, 2003. The Defendant's counsel has been consulted, and does not oppose this motion. Respectfully submitted this 10th day of October, 2003.

s/ Steven A. Miller for William F. Lenihan SCHWABE, WILLIAMSON & W YATT, PC 1420 Fifth Avenue, Suite 3010 Seattle, WA 98101 Phone: (206) 622-1711 Fax: (206) 292-0460 -1SEA/054368/070915/RCO/316139.1

Case 1:91-cv-00984-EGB

Document 12

Filed 10/10/2003

Page 2 of 3

Of Counsel: Steven A. Miller SCHWABE, WILLIAMSON & W YATT 1420 Fifth Avenue Suite 3010 Seattle, WA 98101-2393 Phone: (206) 622-1711 Fax: (206) 292-0460

-2SEA/054368/070915/RCO/316139.1

Case 1:91-cv-00984-EGB

Document 12

Filed 10/10/2003

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify under penalty of perjury that on this 10th day of October, 2003, I caused copies of the foregoing UNOPPOSED MOTION FOR ENLARGEMENT OF TIME TO FILE RESPONSIVE BRIEF AND CROSS-MOTION to be served upon the following individual by facsimile and also by Federal Express. Richard P. Nockett Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 1100 L St., N.W. (8th Floor) Washington, D.C. 20530

s/ Steven A. Miller

-3SEA/054368/070915/RCO/316139.1