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

Case 1:00-cv-00697-JFM

Document 222

Filed 03/16/2006

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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 four days from March 17, 2006 until March 21, 2006 within which to file WE's Reply to Defendant's Response to Plaintiff's Motion for Leave to File its Amended and Supplemental Complaint. This is WE's first request for an enlargement of time for filing of this reply brief. 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 responding to Government discovery requests, audit verification requests, and the Government's motion to extend fact discovery. Counsel for WE also has other pressing matters. The requested enlargement will permit WE and its counsel sufficient time to prepare the reply brief. For the foregoing reasons, we respectfully request that the Court grant this motion and extend the time for WE to reply to the Government's response to WE's Motion for Leave to Amend its Complaint by four days until March 21, 2006.

[28795-0001/DA060730.041.DOC]

Case 1:00-cv-00697-JFM

Document 222

Filed 03/16/2006

Page 2 of 3

Dated: March 16, 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/Donald J. Carney 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/DA060730.041.DOC]

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Case 1:00-cv-00697-JFM

Document 222

Filed 03/16/2006

Page 3 of 3

CERTIFICATE OF SERVICE I certify under penalty of perjury that, on March 16, 2006, I caused a copy of the foregoing "Plaintiff's 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/Donald J. Carney Donald J. Carney

[28795-0001/DA060730.041.DOC]

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