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

Case 1:07-cv-00876-JFM

Document 15

Filed 09/05/2008

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS

YANKEE ATOMIC ELECTRIC COMPANY Plaintiff, v. UNITED STATES OF AMERICA Defendant. No. 07-876C (Senior Judge Merow)

YANKEE ATOMIC'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Pursuant to Rule 6(b) of the Rules of the United States Court of Federal Claims, Yankee Atomic Electric Company ("Yankee Atomic") respectfully requests an enlargement of time of seven (7) days, to and including September 15, 2008, within which to respond to Defendant United States' Motion to Coordinate Discovery and Develop a Litigation Plan for the Spent Nuclear Fuel Cases. Yankee Atomic's response is currently due on September 8, 2008. Counsel for the United States, Marian E. Sullivan, has represented that the government does not oppose this motion. Yankee Atomic requests this additional time due to the press of other litigation matters that have delayed Yankee Atomic's counsel's ability to devote attention to this matter. This case is currently stayed until thirty (30) days after the Federal Circuit issues its mandate in Yankee Atomic Electric Co. v. United States, No. 07-5025 (Fed. Cir.), and as such, the requested oneweek extension will not prejudice any party or slow resolution of the case in any way. For the foregoing reasons, Yankee Atomic respectfully requests that the Court grant this unopposed request for a one-week enlargement of time.

Case 1:07-cv-00876-JFM

Document 15

Filed 09/05/2008

Page 2 of 2

Dated:

September 5, 2008 Respectfully submitted,

Of Counsel: William J. Kayatta, Jr. Jared des Rosiers Michael Wilson Lucus Ritchie Pierce Atwood LLP One Monument Square Portland, ME 04101 (207) 791-1100 (207) 791-1350 (fax)

s/Timothy Heffernan Timothy Heffernan Watt, Tieder, Hoffar & Fitzgerald, L.L.P 8405 Greensboro Drive, Suite 100 McLean, Virginia 22102 (703) 749-1000 (703) 893-8029 (fax) Counsel of Record for Plaintiff Yankee Atomic Electric Company

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