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

Case 1:00-cv-00697-JFM

Document 209

Filed 11/30/2005

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS WISCONSIN ELECTRIC POWER COMPANY, Plaintiff, v. UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) )

No. 00-697C (Senior Judge Merow)

DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Pursuant to Rule 6(b) of the Rules of the United States Court of Federal Claims ("RCFC"), defendant, the United States, respectfully requests an enlargement of time of 14 days, to and including Wednesday, December 14, 2005, within which to serve its responses and objections to plaintiff's second set of production requests. Our responses and objections are currently due on This is defendant's second request

Wednesday, November 30, 2005.

for an enlargement of time for this purpose, the Court having previously granted defendant an enlargement of 30 days. This

request will not affect any dates set forth in the Court's scheduling orders. Counsel for plaintiff has represented that

plaintiff, Wisconsin Electric Power Company, does not oppose this motion. Defendant seeks this enlargement of time because some of the production requests have required the agency representatives to attempt to locate old document records located as far away as the states of Idaho and Washington. The requested enlargement will

permit the Government and its counsel time to continue their

Case 1:00-cv-00697-JFM

Document 209

Filed 11/30/2005

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efforts to respond fully to plaintiff's production requests. Therefore, we respectfully request that the Court grant this motion for an enlargement of time. Respectfully submitted, PETER D. KEISLER Assistant Attorney General DAVID M. COHEN Director s/ Harold D. Lester, Jr. HAROLD D. LESTER, JR. Assistant Director s/ Kevin B. Crawford KEVIN B. CRAWFORD Trial Attorney Commercial Litigation Branch Civil Division Department of Justice Attn: Classification Unit 8th Floor 1100 L Street, N.W. Washington, D.C. 20530 Phone: (202) 305-9640 Fax: (202) 307-2503 Attorneys for Defendant November 30, 2005

OF COUNSEL: JANE K. TAYLOR Office of General Counsel U.S. Department of Energy 1000 Independence Ave., S.W. Washington, D.C. 20585

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Case 1:00-cv-00697-JFM

Document 209

Filed 11/30/2005

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CERTIFICATE OF FILING I hereby certify under penalty of perjury that on November 30, 2005 a copy of this "DEFENDANT'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME" was filed electronically. I understand that

notice of this filing will be sent to all parties by operation of the Court's electronic filing system. filing through the Court's system. Parties may access this

s/ Kevin B. Crawford