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

Case 1:00-cv-00697-JFM

Document 246

Filed 07/18/2006

Page 1 of 3

IN THE UNITED STATES COURT OF FEDERAL CLAIMS

WISCONSIN ELECTRIC POWER COMPANY, Plaintiff, v. THE UNITED STATES, Defendant.

No. 00-697C Senior Judge Merow

PLAINTIFF'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Pursuant to Rule 6(b), plaintiff, Wisconsin Electric Power Company ("WE"), respectfully requests an enlargement of time of seven days from August 18, 2006 until August 25, 2006 within which to complete expert discovery. This is WE's first request for an enlargement of time for expert discovery.1 Counsel for the Government has represented that it does not oppose WE's request for an enlargement of time. Counsel for WE has been actively engaged for the past several weeks in reviewing the Government's expert reports and expert-related productions of documents, and in scheduling, preparing and conducting depositions of Government experts. The requested seven day extension of expert discovery will allow completion of expert discovery in a manner that accommodates the schedules of the Government's experts and Government and

The Government moved to extend its service of expert-related documents on June 7, 2006. WE conditioned its accord with that motion on an extension of expert discovery from July 7, 2006 to August 18, 2006.

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[28795-0001/DA061980.038]

7/18/06

Case 1:00-cv-00697-JFM

Document 246

Filed 07/18/2006

Page 2 of 3

WE counsel. Further, the seven-day extension will not affect other pretrial deadlines in this case. For the foregoing reasons, we respectfully request that the Court grant this motion and extend the time for the completion of expert discovery by seven days until August 25, 2006. Dated: July 18, 2006

Of Counsel: Donald J. Carney Perkins Coie LLP 607 Fourteenth St., NW Washington, D.C. 20005 Tel.: 202-434-1675 Fax: 202-434-1690 [email protected]

s/Richard W. Oehler by s/Emily C.C. Poulin Richard W. Oehler Perkins Coie LLP 1201 Third Avenue, 40th Floor Seattle, Washington 98101-3099 Tel.: 206-583-8419 Fax: 206-583-8500 [email protected] Attorney of Record for Plaintiff Wisconsin Electric Power Company

[28795-0001/DA061980.038]

7/18/06

Case 1:00-cv-00697-JFM

Document 246

Filed 07/18/2006

Page 3 of 3

CERTIFICATE OF SERVICE I certify under penalty of perjury that, on July 18, 2006, 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/DA061980.038]

7/18/06