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

Case 1:07-cv-00352-TCW

Document 6

Filed 07/31/2007

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS PACIFIC GAS AND ELECTRIC COMPANY, ) ) Plaintiff, ) ) v. ) ) THE UNITED STATES, ) ) Defendant. )

No. 07-352C (Judge Wheeler)

DEFENDANT'S UNOPPOSED MOTION FOR EXTENSION OF TIME Pursuant to Rule 6(b) of the Rules of the United States Court of Federal Claims, the Government respectfully requests that the Court enlarge the deadline for the Government to file its response to the complaint by 30 days, from August 6, 2007, until September 5, 2007. This is our first request for an enlargement for this purpose. We have discussed this matter with counsel for the plaintiff and represent that she does not oppose this motion. The additional time is requested so that Government counsel adequately can prepare and file the Government's response to the complaint. We need this additional time because the agency responsible for providing litigation support in this case, the Western Area Power Administration ("WAPA"), has been unable to complete the investigation and assemble the materials necessary to supply a litigation report. We understand that WAPA possesses literally dozens of boxes containing potentially relevant documents, which it is sifting for purposes of providing us a concise litigation report. WAPA has informed us that it expects to have concluded this process within the 30 days requested by this motion. Accordingly, we respectfully request that the Court grant this unopposed motion for enlargement and enlarge the deadline for the Government to file its answer until September 5, 2007.

Case 1:07-cv-00352-TCW

Document 6

Filed 07/31/2007

Page 2 of 2

Respectfully submitted, PETER D. KEISLER Assistant Attorney General JEANNE E. DAVIDSON Director s/ Mark A. Melnick MARK A. MELNICK Assistant Director

s/J. Reid Prouty J. REID PROUTY Trial Attorney Commercial Litigation Branch Civil Division Department of Justice 1100 L Street, N.W. Attn: Classification Unit 8th Floor Washington, D.C. 20530 Tele: (202) 305­7586 Fax: (202) 514-7969 July 31, 2007

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