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

Case 1:03-cv-00288-EJD

Document 27

Filed 05/11/2006

Page 1 of 2

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

No. 03-288C (Chief Judge Damich)

PLAINTIFFS' UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Pursuant to RCFC 6.1, Plaintiffs, Chevron U.S.A. Inc., Texaco Inc., and Texaco Downstream LLC (collectively "Chevron"), respectfully request an enlargement of time of fifteen days, to and including May 30, 2006, within which to file its Opposition to Defendant's Motion to Dismiss. Chevron's Opposition currently is due on May 15, 2006, and this is Chevron's first request for an enlargement of time for this purpose. Defendant does not oppose this motion. Chevron requests the additional time to file its Opposition in order to obtain the declaration of a former employee who is now a third party witness. Seeking to contact this former employee, who has personal knowledge concerning the DESC contracts at issue in this case, which span from 1982 to 1999, has entailed substantial effort. Accordingly, the additional time Chevron requests to file its Opposition is needed for Chevron to confer with the former employee and to prepare and file its Opposition.

Case 1:03-cv-00288-EJD

Document 27

Filed 05/11/2006

Page 2 of 2

CONCLUSION For the foregoing reasons, Chevron respectfully requests that its Unopposed Motion for an Enlargement of Time be granted. Respectfully submitted,

s/ J. Keith Burt J. Keith Burt Mayer, Brown, Rowe & Maw LLP 1909 K Street, N.W. Washington, DC 20006 (202) 263-3208 (phone) (202) 263-3300 (fax) Counsel for Plaintiffs, Chevron U.S.A. Inc., Texaco Inc., and Texaco Downstream LLC May 11, 2006

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