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

Case 1:07-cv-00875-JFM

Document 15

Filed 09/05/2008

Page 1 of 2

IN THE UNITED STATES COURT OF FEDERAL CLAIMS

CONNECTICUT YANKEE ATOMIC POWER COMPANY Plaintiff, v. UNITED STATES OF AMERICA Defendant. No. 07-875C (Senior Judge Merow)

CONNECTICUT YANKEE'S UNOPPOSED MOTION FOR AN ENLARGEMENT OF TIME Pursuant to Rule 6(b) of the Rules of the United States Court of Federal Claims, Connecticut Yankee Atomic Power Company ("Connecticut Yankee") 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. Connecticut Yankee'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. Connecticut Yankee requests this additional time due to the press of other litigation matters that have delayed Connecticut Yankee'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 one-week extension will not prejudice any party or slow resolution of the case in any way.

Case 1:07-cv-00875-JFM

Document 15

Filed 09/05/2008

Page 2 of 2

For the foregoing reasons, Connecticut Yankee respectfully requests that the Court grant this unopposed request for a one-week enlargement of time. 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 Connecticut Yankee Atomic Power Company

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