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

Case 1:00-cv-00697-JFM

Document 174

Filed 11/12/2004

Page 1 of 3

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 seven days, to and including Friday, November 19, 2004, within which to file its pleading in response to plaintiff's complaint. currently due on Friday, November 12, 2004. The response is

Defendant has not

previously requested an enlargement of time for this purpose. Counsel for plaintiff has represented that plaintiff, Wisconsin Electric Power Company, does not oppose this motion. Counsel for the Government needs this brief enlargement of time because, as one of the attorneys assigned to the preparation of the post-trial filings in the cases of Yankee Atomic Electric Company v. United States, No. 98-129C, Connecticut Yankee Atomic Power Company v. United States, No. 98-154C, and Maine Yankee Atomic Power Company v. United States, No. 98-474C, pending before this Court, he has been devoting and will continue to devote a substantial amount of time, including weekends, to completion of that project. This brief enlargement should allow

Case 1:00-cv-00697-JFM

Document 174

Filed 11/12/2004

Page 2 of 3

sufficient time after completion of Government counsel's present work on the Yankee filings to prepare and file the responsive pleading. 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 12, 2004

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 174

Filed 11/12/2004

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CERTIFICATE OF FILING I hereby certify under penalty of perjury that on this 12th day of November, 2004, 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. may access this filing through the Court's system. Parties

s/ Kevin B. Crawford