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

Case 1:08-cv-00074-LJB

Document 6

Filed 04/04/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS ) ) ) Plaintiffs, ) ) v. ) ) UNITED STATES OF AMERICA, ) ) Defendant. ) ______________________________) VICTOR BRISENO, and PAULA BRISENO,

No. 08-74 L Judge Lynn J. Bush

UNOPPOSED MOTION TO ENLARGE TIME WITHIN WHICH TO RESPOND TO PLAINTIFFS' COMPLAINT Pursuant to Rules 6(b) and 6.1 of the Rules of the United States Court of Federal Claims (`RCFC"), Defendant United States of America respectfully submits this unopposed motion for enlargement of time of fourteen days from the current deadline, to and including April 18, 2008, within which to file its Answer or otherwise respond to Plaintiffs' Complaint. In support of its request, Defendant states as follows: 1. Plaintiffs filed their Complaint in this case on February 4, 2008. See Complaint, filed

February 4, 2008 (Doc. 1). The Court's electronic docket indicates that the United States' Answer to the Plaintiffs' Complaint is due April 4, 2008. 2. This enlargement of time is necessary to permit the United States' counsel additional

time to consult with agency counsel and to review the appropriate administrative materials to adequately respond to Plaintiffs' Complaint. The United States therefore requests a two-week extension of the deadline to submit its Answer or otherwise respond to Plaintiffs' Complaint. 3. Pursuant to RCFC 6.1, the undersigned counsel certifies that he has conferred with

William R. Keeler, counsel for Plaintiffs, regarding the relief requested in this motion. Mr. Keeler does not oppose this motion.

Case 1:08-cv-00074-LJB

Document 6

Filed 04/04/2008

Page 2 of 2

4.

The United States has not previously requested or obtained any extension of

deadlines in this matter. This motion is not filed for purposes of delay. The granting of this request will not cause undue prejudice to the parties or to the Court. WHEREFORE, Defendants respectfully request that their motion be GRANTED. Respectfully submitted this 4th day of April, 2008,

RONALD J. TENPAS Assistant Attorney General United States Department of Justice Environment & Natural Resources Division

By:

/s/ Mark S. Barron MARK S. BARRON, Trial Attorney United States Department of Justice Environment & Natural Resources Division Natural Resources Section Ben Franklin Station, P.O. Box 663 Washington, D.C. 20044 Tel. (202) 305-0490/ Fax (202) 305-0506 [email protected] Attorneys for the United States

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