Free Motion for Leave to Exceed Page Limit - District Court of Federal Claims - federal

Case 1:03-cv-00288-EJD

Document 35

Filed 06/15/2006

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS CHEVRON, U.S.A., INC, TEXACO, INC, and TEXACO DOWNSTREAM LLC, Plaintiffs, v. THE UNITED STATES, Defendant. ) ) ) ) ) ) ) ) ) ) )

No. 03-288C (Chief Judge Damich)

DEFENDANT'S MOTION FOR LEAVE TO EXCEED THE PAGE LIMIT Defendant respectfully requests leave to exceed the page limit for its response to Chevron's opposition to our motion to dismiss. Plaintiffs' counsel has informed us that plaintiff does not object to this motion. Pursuant to RCFC 5.2(b), our brief is limited to 20 pages. However, Chevron has obtained leave to exceed the page limit for its opposition, and has filed an 89-page brief. The opposition is the first detailed statement of Chevron's case, contains 12 enumerated arguments, and is accompanied by a voluminous appendix and 40 proposed findings of fact. We estimate that our brief will be approximately 47 pages. For these reasons, defendant respectfully requests leave to exceed the page limit for its response to Chevron's opposition to our motion to dismiss. Respectfully submitted, PETER D. KEISLER Assistant Attorney General

s/ David M. Cohen DAVID M. COHEN Director

Case 1:03-cv-00288-EJD

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OF COUNSEL: DONALD S. TRACY Trial Attorney Defense Supply Center Richmond Richmond, VA 23297

HOWARD M. KAUFER Assistant Counsel Office of Counsel Defense Energy Support Center Ft. Belvoir, VA

s/ Steven J. Gillingham STEVEN J. GILLINGHAM Assistant Director Commercial Litigation Branch Civil Division Attn: Classification Unit 1100 L Street, N.W., 8th Floor Department of Justice Washington, D.C. 20530 Tele: (202) 616-2311 Fax: (202) 353-7988

Attorneys for Defendant June 15, 2006

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Case 1:03-cv-00288-EJD

Document 35

Filed 06/15/2006

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CERTIFICATE OF FILING I hereby certify that on June 15, 2006, a copy of the foregoing document 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. Parties may access this filing through the Court's system. s/ Steven J. Gillingham