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

Case 1:08-cv-00212-SGB

Document 6

Filed 05/23/2008

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS ____________________________________ TAKAHO ESTATES, LLC, a Florida Limited Liability Company, Plaintiff, v. ) ) ) ) ) ) ) ) ) ) ) )

No. 08-212 L Hon. Susan G. Braden

UNITED STATES, Defendant.

DEFENDANT'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME Pursuant to Rule 6.1 of the Rules of the United States Court of Federal Claims ("RCFC"), Defendant, the United States of America, respectfully moves this Court for a thirty (30) day enlargement of time, to and including June 27, 2008, for the filing of its answer or responsive motions to Plaintiff's complaint. Defendant's response is presently due May 27, 2008. Defendant has made no prior requests for an enlargement of time. The grounds for this motion are as follows: 1. Plaintiff filed the present complaint on March 27, 2008, and Defendant's counsel

received the complaint on April 28, 2008. 2. On May 1, 2008, Defendant's counsel submitted a request to the relevant agency,

the Federal Aviation Administration ("FAA"), for a litigation report and any documents necessary to respond to the complaint. On May 15, 2008, the FAA provided counsel with a preliminary report, and on May 22, 2008, the FAA supplemented the initial report with additional documents.

Case 1:08-cv-00212-SGB

Document 6

Filed 05/23/2008

Page 2 of 2

3.

Upon a review of the litigation report and related documents, counsel estimates

that he will need an additional thirty (30) days to obtain further information and documents, and to review, research and prepare Defendant's responses to Plaintiff's complaint, including obtaining the necessary review and approval of said responses by the appropriate employees of the FAA. 4. On May 22, 2008, counsel for Defendant contacted Plaintiff's counsel about this

motion by telephone. On May 23, 2008, Plaintiff's counsel authorized Defendant's counsel that it may represent to the Court that Plaintiff does not oppose this motion. Wherefore, pursuant to RCFC 6.1, Defendant respectfully requests that its time for filing a response to Plaintiff's complaint be extended thirty (30) days from May 27, 2008 to and including June 27, 2008. Respectfully submitted this 23rd day of May, 2008. RONALD J. TENPAS Assistant Attorney General

s/E. Kenneth Stegeby E. KENNETH STEGEBY Trial Attorney Natural Resources Section Environment & Natural Resources Division U.S. Department of Justice P. O. Box 663, Washington, D.C. 20044-0663 Telephone: 202.616.4119 Facsimile: 202.305.0506 Email: [email protected]

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