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

Case 1:00-cv-00697-JFM

Document 391

Filed 04/18/2008

Page 1 of 3

IN THE UNITED STATES COURT OF FEDERAL CLAIMS WISCONSIN ELECTRIC POWER COMPANY, Plaintiff, v. THE UNITED STATES, Defendant. PLAINTIFF'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Plaintiff Wisconsin Electric Power Company ("WE") respectfully requests an enlargement of 30 days from April 21, 2008 until May 21, 2008 for the parties to confer regarding mutually convenient dates for oral argument and to notify the Court of the proposed dates. This is the first enlargement that WE has sought for this activity. Government counsel has indicated that the Government does not oppose this motion. On October 26, 2007, the parties filed a Joint Stipulation regarding a post-trial briefing schedule and a proposal to conduct oral argument during the first two weeks of May 2008. In an October 29, 2007 Order, the Court accepted the schedule contained in the Joint Stipulation and requested that the parties confer regarding acceptable oral argument dates during the period of May 5 ­ 16, 2008 and notify the Court of those proposed oral argument dates by April 21, 2008. The Joint Stipulation and Order was premised on the Government filing its post-trial pleadings on February 8, 2008. In fact, after enlargements of time, the Government filed its post-trial pleadings on March 25, 2008. Based on Court Orders, WE's post-trial reply pleadings are now due on May 13, 2008. Further, given the length of the Government's posttrial pleadings (more than 500 pages), WE may well request an enlargement of time for the filing of its reply pleadings. (Senior Judge Merow)

No. 00-697C

28795-0001/LEGAL14190839.1

Case 1:00-cv-00697-JFM

Document 391

Filed 04/18/2008

Page 2 of 3

In these circumstances, WE believes that it makes sense to extend the time for the parties to confer and to notify the Court regarding acceptable oral argument dates for a period of thirty days. For the foregoing reasons, WE respectfully requests that the Court grant Plaintiff's Unopposed Motion for an Enlargement of Time. Dated: April 18, 2008 Respectfully submitted, s/ Richard W. Oehler by s/Emily C.C. Poulin Richard W. Oehler Perkins Coie LLP 1201 Third Avenue, Suite 4800 Seattle, Washington 98101-3099 (206) 583-8419 Attorneys for Plaintiff WISCONSIN ELECTRIC POWER COMPANY

Of Counsel: Donald J. Carney Perkins Coie LLP 607 Fourteenth Street, N.W. Washington, D.C. 20005 (202) 434-1675

-228795-0001/LEGAL14190839.1

Case 1:00-cv-00697-JFM

Document 391

Filed 04/18/2008

Page 3 of 3

CERTIFICATE OF SERVICE
I certify under penalty of perjury that, on April 18, 2008, I caused a copy of the foregoing "Plaintiff's Unopposed Motion for An Enlargement of Time" to be 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/ Emily C.C. Poulin Emily C.C. Poulin

28795-0001/LEGAL14190839.1