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

Case 1:00-cv-00697-JFM

Document 167

Filed 06/01/2004

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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 three days, to and including Friday, June 4, 2004, within which to file its response to plaintiff's motion for partial summary judgment on liability. 2004. The response is currently due on Monday, June 1,

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. As part of his review of the evidence, counsel for the Government needs this brief enlargement of time to complete his review of the plaintiff's document production. Therefore , we

respectfully request that the Court grant this motion for an enlargement of time.

Case 1:00-cv-00697-JFM

Document 167

Filed 06/01/2004

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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 June 1, 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 167

Filed 06/01/2004

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CERTIFICATE OF FILING I hereby certify under penalty of perjury that on this 1st day of June, 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