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

Case 1:88-cv-00508-EGB

Document 91

Filed 07/06/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS

) ) Plaintiff, ) v. ) ) THE UNITED STATES, ) ) Defendant, ) _________________________________________ )

THE NAVAJO NATION,

No. 508-88L Senior Judge Eric G. Bruggink

JOINT MOTION FOR ENLARGEMENT OF TIME In the parties' Joint Status Report of May 4, 2007, the parties proposed submitting a further status report on July 9, 2007. As explained below, the parties require an additional two weeks in which to file their next joint status report. As stated in the status report of May 4, 2007, Plaintiffs provided Defendant with certain discovery responses on April 30, 2007. Defendant continues to review those responses. In addition, Defendant has identified additional documents located at various Bureau of Indian Affairs offices in New Mexico and Arizona, as well as at a federal records center in Lenexa, Kansas, that may be responsive to discovery requests served on Defendant by Plaintiffs. Defendant has been and continues to make the necessary arrangements with the United States Department of the Interior for identifying relevant documents and providing them to Plaintiffs as efficiently as possible. Finally, the parties agree that they could use approximately two more weeks to determine how best to proceed with the litigation. Therefore, for the reasons stated above, the parties respectfully request an additional fourteen (14) days, until July 23, 2007, in which to file their next status report. The parties have

Case 1:88-cv-00508-EGB

Document 91

Filed 07/06/2007

Page 2 of 3

not previously requested an enlargement of time for the filing of their joint status report. This motion was jointly prepared by counsel for the parties. Dated: July 6, 2007 Respectfully submitted, BRUCE R. GREENE M. CATHERINE CONDON Greene, Meyer & McElroy, P.C. 1007 Pearl St., Ste. 220 Boulder, Colorado 80302 (303) 442-2021 (phone) (303) 444-3490 (fax) PETER J. OSETEK 412 E. Huron Street Ann Arbor, Michigan 48104 (734) 769-4500 Counsel for the NAVAJO NATION By: s/ Bruce R. Greene by s/ G. Evan Pritchard Bruce R. Greene

WILLIAM J. SHAPIRO Trial Attorney United States Department of Justice Environment and Natural Resources Division Natural Resources Section 501 I Street, Suite 9-700 Sacramento, California 95814 (916) 930-2207 (phone) (916) 930-2210 (fax) EVAN PRITCHARD Trial Attorney United States Department of Justice Environment and Natural Resources Division Natural Resources Section 601 D Street, NW Washington, DC 20004 (202) 305-0203 (phone) (202) 305-0506 (fax) 2

Case 1:88-cv-00508-EGB

Document 91

Filed 07/06/2007

Page 3 of 3

Counsel for the UNITED STATES OF AMERICA By: s/ William J. Shapiro by s/ G. Evan Pritchard William J. Shapiro

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