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

Case 1:08-cv-00072-TCW

Document 7

Filed 03/25/2008

Page 1 of 3

IN THE UNITED STATES COURT OF FEDERAL CLAIMS

HOOPA VALLEY TRIBE,

) ) Plaintiff, ) ) ) THE UNITED STATES OF AMERICA, ) ) Defendant. ) ___________________________________ )

Case No. 08-72 L Judge Lawrence S. Margolis

CONSENTED MOTION FOR EXTENSION OF TIME Pursuant to RCFC 6.1, Defendant hereby moves for an enlargement of time up to and including June 2, 2008, to answer or otherwise respond to Plaintiff's Complaint. Defendant's answer or other response is currently due April 1, 2008. This is Defendant's first motion for an extension of time to respond to Plaintiff's Complaint. In support of this motion, Defendant states as follows: 1. 2. On February 1, 2008, Plaintiff filed its Complaint in this Court. Upon receiving Plaintiff's Complaint, the undersigned contacted the

Department of the Interior and determined that more time was required to appropriately respond to Plaintiff's complaint due to the complexity of the issues involved and counsel's briefing and obligations in other cases; 3. complaint. 4. The undersigned counsel consulted with Mr. Thomas Schlosser, counsel Accordingly, Defendant requires additional time to respond to Plaintiff's

for Plaintiff, who stated that he did not object to an extension of time. 5. No other scheduling will be affected by an extension.

WHEREFORE, Defendant respectfully requests that this motion be GRANTED.

Case 1:08-cv-00072-TCW

Document 7

Filed 03/25/2008

Page 2 of 3

Submitted this 25th day of March, 2008. RONALD J. TENPAS Assistant Attorney General s/ Devon Lehman McCune Devon Lehman McCune, Trial Attorney U.S. Department of Justice Environment & Natural Resources Division Natural Resources Section 1961 Stout St., 8th Floor Denver, CO 80294 (303) 844-1487 (tel.) (303) 844-1350 (fax) [email protected]

OF COUNSEL: SCOTT BERGSTROM Department of the Interior Office of the Solicitor

-2-

Case 1:08-cv-00072-TCW

Document 7

Filed 03/25/2008

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that on March 25, 2008, I filed the foregoing CONSENTED MOTION FOR EXTENSION OF TIME was electronically sent via the CM/ECF system by the United States Court of Federal Claims on the following party:

Thomas P. Schlosser Email: [email protected]

s/ Devon Lehman McCune Devon Lehman McCune, Trial Attorney U.S. Department of Justice Environment & Natural Resources Division Natural Resources Section 1961 Stout St., 8th Floor Denver, CO 80294 (303) 844-1487 (tel.) (303) 844-1350 (fax) [email protected]

-3-