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

Case 1:00-cv-00697-JFM

Document 203

Filed 10/28/2005

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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 30 days, to and including Wednesday, November 30, 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 first request for This request will not

Monday, October 31, 2005.

an enlargement of time for this purpose.

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 counsel of record in this matter and the other attorneys working on this case have been actively engaged in taking depositions and attending to other pretrial activities in this litigation for the past several weeks. Additionally, there will be a number of The

additional depositions in this matter in the coming weeks.

requested enlargement will permit the Government and its counsel

Case 1:00-cv-00697-JFM

Document 203

Filed 10/28/2005

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sufficient time 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 October 28, 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

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CERTIFICATE OF FILING I hereby certify under penalty of perjury that on October 28, 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