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

Case 1:00-cv-00697-JFM

Document 202

Filed 10/27/2005

Page 1 of 3

IN THE UNITED STATES COURT OF FEDERAL CLAIMS WISCONSIN ELECTRIC POWER COMPANY, Plaintiff, v. THE UNITED STATES, Defendant. PLAINTIFF'S MOTION FOR AN ENLARGEMENT OF TIME Pursuant to Rule 6(b), plaintiff, Wisconsin Electric Power Company ("WE"), respectfully requests an enlargement of time of thirty days from November 2, 2005 until December 2, 2005 within which to serve WE's responses and objections to the Government's Third Set of Interrogatories and Third Set of Requests for the Production of Documents. This is WE's first request for an enlargement of time for service of these responses. 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 defending and taking depositions in this matter as well as attending to other pretrial activities in this litigation. In addition, there will be a number of additional depositions in this matter in the coming weeks. Counsel for WE also has had to attend to other pressing matters. The requested enlargement will permit WE and its counsel sufficient time to respond fully to the Government's discovery requests.

No. 00-697C Senior Judge Merow

[28795-0001-000000/DA052980.024]

10/27/05

Case 1:00-cv-00697-JFM

Document 202

Filed 10/27/2005

Page 2 of 3

For the foregoing reasons, we respectfully request that the Court grant this motion and extend the time for WE to respond to the Government's third set of discovery requests by thirty days until December 2, 2005. Dated: October 27, 2005

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

[28795-0001-000000/DA052980.024]

10/27/05

Case 1:00-cv-00697-JFM

Document 202

Filed 10/27/2005

Page 3 of 3

CERTIFICATE OF SERVICE I certify under penalty of perjury that, on October 27, 2005, 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

[28795-0001-000000/DA052980.024]

10/27/05