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

Case 1:89-cv-00218-EJD

Document 148

Filed 04/06/2006

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS

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THE CHEROKEE NATION OF OKLAHOMA, Plaintiff, and PATTON BOGGS LLP, Intervenor-Plaintiff v. THE UNITED STATES,

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Case No. 89-218L

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THE CHOCTAW NATION OF OKLAHOMA AND THE CHICKASAW NATION, Plaintiffs,

Defendant.

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Case No. 89-630L

THE UNITED STATES,

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CHEROKEE NATION'S UNOPPOSED MOTION FOR EXTENSION OF TIME TO RESPOND TO PATTON BOGGS' CROSS-MOTION FOR SUMMARY JUDGMENT The Cherokee Nation, by and through undersigned counsel, respectfully moves for an extension of time to and including May 12,2006 within which to file the Nation's Response to Patton-Boggs' Cross-Motion for Summary Judgment. In support of this motion, the Nation states as follows:

Defendant.

Case 1:89-cv-00218-EJD

Document 148

Filed 04/06/2006

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1.

Under the Court rules, the Cherokee Nation's response to Patton-Boggs' Cross-

Motion for Summary Judgment is due on April 17,2006. This Court, by order dated March 28, 2006, granted the United States' uncontested motion for an enlargement of time to file, by May 8,2006, the United States' response to Patton Boggs' cross-motion and Patton Boggs' request to file its reply two weeks after the last response is filed.

2. Due to the demands of other litigation, undersigned counsel finds they need additional time to respond to Patton Boggs' cross-motion. Undersigned counsel seeks a few additional days to after May sth do this, as the principal attorney handling this matter for the Cherokee Nation, Arthur Lazarus, Jr., will be out of town on travel from April 26 through May 7. The additional time will allow him to complete the work on the response upon his return.

3. The Cherokee Nation's request for an enlargement of time will not unduly delay the
proceedings on this matter.

4. Undersigned counsel conferred with counsel of record for Intervenor Patton Boggs and
Defendant United States, and is authorized to state that both consent to this request for an extension of time and that Patton Boggs would continue to have two weeks from the date the last response is filed, to file a joint reply.

Case 1:89-cv-00218-EJD

Document 148

Filed 04/06/2006

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WHEREFORE, the Cherokee Nation respectfully prays that the Nation's motion for an extension of time to and including May 12 within which to file its response to Patton Boggs' Cross-Motion for Summary, be granted.

Respectfully submitted, April 6, 2006

f Chambers,d ndreson & Perry LLP Sonosky, l Sachse, h
1425 K Street, N.W., Suite 600 Washington, D.C. 20005 (202) 682-0240 (202) 682-0249 (fax) alazarus@,sonosky.com

EL,flnw A ,

Special Counsel for Plaintiff Cherokee Nation Of Counsel: Lloyd Benton Miller Donald J. Simon Anne D. Noto Sonosky, Chambers, Sachse, Endreson & Perry LLP 1425 K Street, N.W., Suite 600 Washington, D.C. 20005 (202) 682-0240 (202) 682-0249 (fax) llovd@,sonoskv.net dsimon@,sonosky.com anoto@,sonoskv.com